JUDGMENT :

K.R. SHRIRAM J.

1. Rule. Rule made returnable forthwith and heard and disposed at the admission stage itself with the consent of the parties.

Heard, Shri Nankani, Shri Anil Singh and considered the pleadings and written submissions.

2. Petitioner originally filed the petition challenging the communication dated 25th January 2021 withdrawing the earlier communication dated 21st October 2020 issued by the office of Chief Commissioner of Income Tax, Mumbai. By this communication dated 21st October 2020, petitioner was informed that they are eligible for resolution of tax disputes under the provisions of the Direct Tax Vivad Se Vishwas Act 2020 (DTVSV Act). According to petitioner, relying on this communication petitioner had filed several applications for resolution of tax disputes. It is petitioner’s case that the stand of respondents is contrary to the plain language of Section 9(c) of the DTVSV Act.

3. Petitioner is desirous of availing the benefit of DTVSV Act with respect to certain pending income tax litigations before various appellate levels. By an application dated 15th April 2020, petitioner sought clarification from the revenue with respect to its eligibility under th