Tax Planning
Dispute Resolution
11 min read
April 9, 2025

Vivad Se Vishwas Scheme 2024: Should You Settle Your Tax Dispute Before June 2025?

Comprehensive analysis of dispute resolution scheme, waiver of interest and penalties, eligible disputes, calculation, and when it makes sense

Written by

CA Ashama Rajawat

One-Time Opportunity
Deadline: June 30, 2025

Vivad Se Vishwas 2024 allows taxpayers to settle pending tax disputes by paying disputed tax amount with waiver of interest and penalties. Deadline: June 30, 2025.

What is Vivad Se Vishwas Scheme?

Launched in Budget 2024, Vivad Se Vishwas 2.0 is the government's amnesty scheme to reduce pending tax litigation. Pay only disputed tax amount, get full waiver of interest, penalty, and prosecution.

Key Benefits
  • • 100% waiver of interest
  • • 100% waiver of penalty
  • • Immunity from prosecution
  • • Case closed permanently (no appeal by department)
  • • Pay in installments (up to 3 years in some cases)

Eligible Disputes

Covered
  • Appeals pending before CIT(A)
  • Appeals pending before ITAT
  • Cases in High Court or Supreme Court
  • Disputed assessments (Section 143(3), 147, 153A)
  • Penalty orders (Section 271, 271AAB, etc.)
Not Covered
  • Wealth Tax, Gift Tax disputes
  • Search & seizure cases (Section 132)
  • Undisclosed foreign assets
  • Cases involving prosecution already filed

How Much to Pay?

ScenarioAmount Payable
You filed appeal against tax demand
100% of disputed tax
(0% interest, 0% penalty)
Department lost at lower level
0%
(if you won completely)
Partial victory for both sidesPro-rata disputed amount

Real Calculation Example

Case Study: Income Addition Dispute

Assessment Order:

  • • Disputed income addition: ₹50 lakh
  • • Tax @ 30%: ₹15 lakh
  • • Interest @ 1%: ₹3 lakh
  • • Penalty (Section 271): ₹15 lakh
  • Total demand: ₹33 lakh

Without Scheme:

Fight in court, pay ₹33L if you lose + litigation cost ₹2-5L

With Vivad Se Vishwas:

  • • Pay only disputed tax: ₹15 lakh
  • • Interest waived: ₹3 lakh saved
  • • Penalty waived: ₹15 lakh saved
  • Total savings: ₹18 lakh!

Application Process

1

File Declaration

Online on income tax portal → Form VsV-1

2

Pay Amount

Calculate disputed tax, pay via challan

3

Withdraw Appeals

Withdraw pending appeals from CIT(A)/ITAT/Court

4

Get Certificate

Income Tax Department issues discharge certificate (Form VsV-2)

When It Makes Sense

When to Opt for Vivad Se Vishwas
  • Weak case: Your appeal has low chances of success
  • High interest/penalty: Interest & penalty > disputed tax
  • Litigation fatigue: Case dragging for 5+ years
  • Business impact: Pending litigation hurting credit rating, funding

When to Avoid

  • Strong case: You're likely to win in tribunal/court
  • Low disputed tax: ₹1-2 lakh - fight and win
  • Precedent exists: Favorable High Court judgment on same issue

Important Dates

Scheme Announcement: July 23, 2024 (Budget)

Application Deadline: June 30, 2025

Payment Deadline: July 31, 2025 (full payment) or installments allowed

Conclusion

Decide Wisely Before June 30, 2025

Vivad Se Vishwas 2024 is a pragmatic solution for taxpayers stuck in endless litigation. If interest & penalty waiver saves more than litigation cost + time value, settle. But don't rush - analyze your case strength, consult CA/lawyer, compare total cost of settlement vs continuing litigation. Deadline is June 30, 2025 - decide wisely.

Should You Opt for Vivad Se Vishwas? Let's Analyze

CA Ashama Rajawat can review your pending disputes, calculate settlement amount vs litigation cost, and help you make an informed decision.