The Central Board of Direct Taxes (CBDT) has notified 30 April 2025 as the final date for taxpayers to file declarations regarding tax arrears under the Direct Tax Vivad se Vishwas Scheme, 2024. According to Notification S.O. 1650 (e), issued on 8 April 2025, one must submit the declaration to the designated authority on or before this date.
The Income Tax Department announced the update via its official handle on X (formerly Twitter) on 9 April 2025, reiterating that the scheme offers a settlement mechanism for disputes related to income tax. This marks the first instance of a formal deadline being issued under the current version of the scheme.
Key Dates:
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Scheme Operational Since: 1 October 2024
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Cut-off Date for Pending Appeals: 22 July 2024
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Last Date to File Declaration: 30 April 2025
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Declaration Form: Form 1
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Certification Form: Form 3
Objective of the Vivad se Vishwas Scheme
Finance Minister Nirmala Sitharaman introduced the Vivad se Vishwas Scheme, 2024, as part of the Union Budget in July 2024 and made it operational on 1 October 2024. It aims to reduce litigation by providing taxpayers with an opportunity to settle outstanding disputes with the Income Tax Department by paying a reduced amount, thereby avoiding protracted legal proceedings.
The 2024 scheme is an updated iteration of a similar scheme launched in 2020, which saw moderate success. The latest version focuses on increasing compliance and reducing the backlog of appeals pending across various tax appellate forums.
Key Provisions and Eligibility
According to the CBDT, the Vivad se Vishwas Scheme applies only to cases where appeals or proceedings were pending as of 22 July 2024. Taxpayers can still apply if their appeals were active on the specified date, even if the authorities dismissed or disposed of them later. This includes appeals pending before the Commissioner (Appeals), Income Tax Appellate Tribunal (ITAT), High Courts, or the Supreme Court.
Chartered Accountant Pratibha Goel, a partner at Delhi-based PD Gupta & Company, confirmed: “A taxpayer can apply for this scheme if the matter is pending before any appellate authority as on 22 July 2024. Eligible taxpayers must file a Declaration in Form 1 before 30 April 2025 to receive the benefits under the scheme.”
The CBDT clearly states that the scheme does not cover proceedings pending before the Income Tax Settlement Commission. It also excludes review petitions pending before the High Courts or the Supreme Court.
To assist applicants, the Income Tax Department has uploaded a detailed set of Frequently Asked Questions (FAQs) on its official portal. These provide clarifications on eligibility, calculation of disputed tax, and procedural steps involved in filing the declaration.
Filing Process and Form Requirements
Taxpayers must submit a Declaration in Form 1 to the designated authority to avail the scheme. This must be done by the deadline of 30 April 2025. Upon submission, the designated authority will review the declaration and issue a certificate in Form 3, confirming the particulars of the dispute and the amount payable.
The taxpayer must make the payment within the prescribed time frame after the authority issues the certificate. Failure to comply with the deadline or to pay the determined amount will render the declaration void.
Scope and Limitations
The Vivad se Vishwas Scheme is open to both individual taxpayers and companies, provided the appeals relate to direct tax matters. It covers disputes involving income tax, surcharge, cess, and interest but does not extend to penalties or prosecution proceedings unless explicitly mentioned in the FAQs.
Cases eligible for settlement include those:
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Pending before the Commissioner (Appeals), ITAT, High Courts, or Supreme Court as on 22 July 2024.
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Where the appeal has been disposed of after 22 July 2024 but was pending on that date.
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Where the Department has filed the appeal or cross-appeal.
Cases that are not eligible include:
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Matters pending before the Income Tax Settlement Commission.
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Review petitions filed before High Courts or the Supreme Court.
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Disputes involving search cases or cases where assessments were made under section 153A or 153C of the Income Tax Act.
Professional Views
Chartered Accountant Kinjal Bhuta, secretary of the Bombay Chartered Accountants’ Society, noted the significance of this deadline: “This is the first time that a definitive date has been notified. Taxpayers should assess their cases carefully and decide on opting into the scheme before the end of April.”
Tax professionals have welcomed the clarity provided by the CBDT regarding the scope of the scheme and the eligibility of cases. However, some have suggested that the scheme could be more inclusive if it allowed for additional types of disputes or extended the deadline to accommodate complex appeals.
Government’s Broader Objectives
The government has been keen on reducing the volume of litigation in the direct tax space. Data from the Income Tax Department shows a substantial number of appeals pending at various levels, leading to delayed resolution and resource inefficiencies. The government introduced the Vivad se Vishwas Scheme as part of broader reforms to resolve tax disputes and improve the ease of doing business.
By providing a mechanism for taxpayers to voluntarily settle disputes, the government hopes to enhance revenue collection while minimising the cost of enforcement and legal processes.
The 30 April 2025 deadline provides taxpayers with a limited window to evaluate their pending cases and consider opting for a one-time settlement.
Vakilsearch can help you prepare and file the required forms on time. Our tax experts ensure your application meets all eligibility requirements—no last-minute confusion, no missed deadlines. Contact us today.
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