Official Deadline: File for Vivad se Vishwas 2024 Scheme by April 30

In an important initiative aimed at minimizing tax litigation and offering relief to taxpayers, the Central Board of Direct Taxes (CBDT) has set the ultimate deadline for engaging in the Direct Tax Vivad se Vishwas Scheme, 2024 (VSV 2.0). If you have unresolved direct tax disputes, this is a vital, time-sensitive opportunity you must seize.

The CBDT, through Notification No. S.O. 1650(E) dated April 8, 2025, has officially confirmed that April 30, 2025, is the final date for submitting declarations under this scheme.

Let’s explore the details of the Vivad se Vishwas Scheme 2024 and the importance of this deadline.

Introduced in the Union Budget 2024-25 and beginning on October 1, 2024, the VSV Scheme 2.0 offers taxpayers a means to amicably resolve their outstanding direct tax disputes. Its goals include:

- Alleviating the burden of long-standing tax litigation for both taxpayers and tax authorities.

- Providing taxpayers with certainty and peace of mind.

- Generating timely revenue for the government.

Essentially, the scheme permits eligible taxpayers to remit a specified amount (usually the disputed tax) and, in exchange, receive a waiver of interest and penalties, as well as protection from prosecution concerning the settled issue.

The scheme is accessible to taxpayers with direct tax disputes that were unresolved as of July 22, 2024. This generally covers cases where:

- Appeals, writs, or Special Leave Petitions (initiated by either the taxpayer or the tax department) were pending before the Commissioner of Income Tax (Appeals) [CIT(A)], Income Tax Appellate Tribunal (ITAT), High Courts, or the Supreme Court.

- Matters were pending with the Dispute Resolution Panel (DRP).

- Revision requests under Section 264 of the Income-tax Act were in progress before the Principal Commissioner/Commissioner of Income Tax.

Significant Eligibility Expansion: In Order No. 8/2025 dated January 20, 2025, the CBDT clarified that the scheme also encompasses cases where:

- An assessment order or appellate order was issued on or before July 22, 2024.

- The deadline for filing an appeal against such an order had not lapsed as of July 22, 2024.

- The appeal was filed after July 22, 2024, but within the prescribed time limit (without needing to submit a request for delay condonation).

Certain cases, including those before the Settlement Commission or related to specific types of search assessments, might be excluded (refer to the official documents for precise exclusions).

Choosing the Vivad se Vishwas Scheme 2.0 provides considerable benefits:

- Waiver of Interest & Penalty: The most appealing benefit is the total waiver of disputed interest and penalties linked to the settled tax amount.

- Immunity from Prosecution: Taxpayers are protected from the commencement of prosecution actions regarding the settled tax dues under the scheme.

- Dispute Resolution: Offers a pathway to achieve closure for prolonged tax disputes.

- Cost & Time Savings: Helps avoid the considerable time, effort, and expenses associated with ongoing litigation.

The CBDT Notification dated April 8, 2025, explicitly states that April 30, 2025, marks the deadline for filing the essential declaration (Form 1) with the designated authority to participate in the VSV 2.0 scheme.

There is no suggestion of any further extension. Missing this deadline implies forfeiting the chance to benefit from the advantages provided under this particular dispute resolution opportunity.

- Filing a Declaration: Taxpayers must submit a declaration in Form 1 for each dispute they wish to resolve, along with a commitment to withdraw associated appeals or petitions, by April 30, 2025.

- Evaluation: The Designated Authority (DA) assesses the declaration and calculates the necessary payment by the taxpayer according to the scheme's regulations. They then provide a certificate (Form 2) outlining this within 15 days.

- Making Payment: The taxpayer is required to pay the specified amount indicated in the certificate within 15 days of its receipt.

- Notification: After making the payment, the taxpayer must notify the DA using Form 3, supplying proof of payment and confirmation of the withdrawal of appeals or petitions.

- Final Confirmation: Upon receiving the notification and verifying compliance, the DA issues a final order (Form 4) confirming the complete and final resolution of the dispute.

(Note: The specific amount payable can differ based on the type of dispute—such as contested tax, interest, or penalties—and may depend on when the original appeal was submitted relative to particular dates indicated in the scheme guidelines. For exact calculations, refer to the official scheme notification or seek advice from a tax professional.)

Although no new declarations can be made after this deadline, any submissions made on or before April 30, 2025, will still be processed according to the timelines established in the VSV 2.0 scheme. The payment obligation arises only after the DA determines the payable amount based on an accepted declaration.

If you have outstanding direct tax disputes as of July 22, 2024 (including those impacted by the expanded eligibility), the Vivad se Vishwas Scheme 2024 presents a significant opportunity for resolution. With the deadline of April 30, 2025, approaching quickly, it's essential to:

- Review your unresolved disputes.

- Evaluate the potential advantages of the scheme (such as waiving interest and penalty, achieving finality).

- Consult with your tax advisor to comprehend eligibility, calculate the likely payment amount, and ensure correct completion of Form 1.

Seize this limited opportunity to effectively resolve long-standing tax litigation and achieve certainty.

This blog post offers general insights regarding the Direct Tax Vivad se Vishwas Scheme, 2024, based on publicly accessible notifications and information as of April 29, 2025. It does not serve as professional tax or legal counsel. For guidance tailored to your situation, please consult a qualified tax advisor before making any decisions.

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