Tax Litigation & Representation

VIVAD SE VISHWAS 2.0 (VSV 2.0)

Vivad se Vishwas 2.0 (VSV 2.0) — Key Facts:

1. The Direct Tax Vivad se Vishwas Scheme, 2024 (VSV 2.0) was introduced by the Finance Act 2024.

2. Effective date: 1 October 2024 (CBDT Notification No. 104/2024 dated 15 October 2024).

3. Covers disputes pending as of 22 July 2024 (date of Finance Act 2024 Royal Assent) before:
• Commissioner (Appeals)
• ITAT
• High Courts
• Supreme Court
• Dispute Resolution Panel (DRP)
• Revision under s.264

4. CBDT Rules: The Direct Tax Vivad se Vishwas Rules, 2024 (notified alongside the Act).

5. Payment structure:
• If paid before 31 December 2024: 100% of disputed tax (no interest, no penalty)
• If paid after 31 December 2024: 110% of disputed tax
• Where only interest/penalty is in dispute: 25% before 31 Dec, 30% after

6. Forms:
• Form VSV-1: Declaration to be filed by taxpayer
• Form VSV-2: Certificate issued by the Designated Authority
• Form VSV-3: Final payment undertaking

7. VSV 1.0 (Finance Act 2020) closed 31 January 2021; VSV 2.0 is its successor and covers all fresh disputes.

Tax litigation services cover the disputes between the taxpayer and the tax authorities under the Income-tax Act 1961 and the indirect tax statutes — the assessment and the penalty proceedings, the appeals to the Commissioner (Appeals) under Section 246A, the Income Tax Appellate Tribunal under Section 253, the High Court and the Supreme Court, the revision applications, and the settlement and the alternative dispute resolution. The litigation is the structured process through which the taxpayer's position is argued against the department's, and its course is decided by the drafting, the evidence and the representation.

The tax dispute begins with the assessment or the demand and runs through the appellate machinery — the CIT(A), the ITAT, the High Court — with each stage carrying its own procedure, its own timelines and its own rules of the evidence. The litigation is the taxpayer's defence of the position the records support, and the quality of the grounds, the submissions and the representation decides the outcome at each stage.

The cost of a mishandled tax dispute is the demand that stands: the addition that was never appealed in time, the position that was never argued with the records, the penalty that was never challenged — each fixed by the process the taxpayer did not run properly.

This service is for taxpayers in disputes with the tax authorities. We review the assessment, the demand and the notices, prepare the grounds and the submissions under the applicable sections, file the appeals and the applications within the prescribed periods, represent the taxpayer before the authorities and the tribunals, and carry the matter through the appellate hierarchy to the final order.