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TMI Blog2020 (11) TMI 485X X X X Extracts X X X X X X X X Extracts X X X X ..... of the President on 17th March 2020 and published in the Gazette of India on 17th March 2020. In terms of the said Act, the assessee has been given an option to put an end to the tax disputes, which may be pending at different levels either before the First Appellate Authority or before the Tribunal or before the High Court or before the Hon'ble Supreme Court of India. The assessee is given liberty to restore this appeal in the event the ultimate decision to be taken on the declaration to be filed by the assessee under Section 4 of the said Act is not in favour of the assessee. If such a prayer is made, the Registry shall entertain the prayer without insisting upon any application to be filed for condonation of delay in restorati ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... without considering the carry forward loss especially when it was held in the decision relied in the case of Yokogawa India Limited that the deduction u/s.10A and 10B is to be allowed while computing gross total income of eligible undertaking under Chapter-IV of the Income Tax Act? 2. We have heard M/s.Hemalatha, learned counsel appearing for the appellant/Revenue and Mr.R.Sandeep Begamar, learned counsel for the respondent/assessee. 3. It may not be necessary for this Court to decide the Substantial Questions of Law framed for consideration on account of certain subsequent developments. The Government of India enacted the Direct Tax Vivad Se Vishwas Act, 2020 (Act 3 of 2020) to provide for resolution of disputed tax and for matter ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the issue is pending before the Income Tax Appellate Tribunal. The filing of the declaration is as per Section 4 of the Act and the particulars to be furnished are also mentioned in the Sub Sections of Section 4. Section 5 of the Act deals with the time and manner of the payment and Section 6 deals with Immunity from initiation of proceedings in respect of offence and imposition of penalty in certain cases. Section 9 of the Act deals with cases, where the Act 3 of 2020 will not be applicable. 6. We are informed by the learned counsel for the respondent/assessee that the assessee has already filed the declarations under Section 4 of the Act on 12.05.2020. 7. In the light of the fact that the assessee has already availed the benefit und ..... X X X X Extracts X X X X X X X X Extracts X X X X
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