2020 (12) TMI 184

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..... application/declaration in accordance with the Direct Tax Vivad Se Vishwas Act, 2020 (Act 3 of 2020) and pass appropriate orders as expeditiously as possible. 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, th .....

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..... wing substantial questions of law: 1. Whether on the facts and in the circumstances of the case, the Tribunal was right in setting aside the well reasoned order passed by the Assessing officer for reexamination, especially when the assessing officer had duly examined all the material placed while passing the assessment order? 2. Whether on the facts and in the circumstances of the case, .....

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..... d facts are true and only thereafter the burden would shift to the department? 3. We have heard Mrs.R.Hemalatha, learned Senior Standing Counsel appearing on behalf of the appellant and Mr.P.Hari, learned counsel appearing for the respondent. 4. The learned counsel appearing for the respondent/assessee submits that the respondent/assessee has filed the declaration/ undertaking under the Vi .....

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