JUDGMENT :

DHIRAJ SINGH THAKUR, J.

1. The petitioner prays for issuance of a writ of mandamus to respondent No. 2 to revise the impugned Form-3 dated 27th September 2021 issued under the provisions of Direct Tax Vivad Se Vishwas Act, 2020 (‘DTVSV Act’) by giving credit and taking into consideration the amounts already paid under the Income Declaration Scheme, 2016.

2. Briefly stated the material facts are as under:

An Income Declaration Scheme, 2016 (‘IDS’) was introduced by Chapter IX of the Finance Act, 2016 which envisaged granting an opportunity to persons to come forward and declare their undisclosed income and pay the applicable tax, surcharge and penalty on the income so disclosed. The Scheme also provided to such a declarant, among others, immunity from prosecution. The petitioner, with a view to seek benefit under the IDS filled up Form- 1, dated 30th September 2016 for the relevant year and disclosed an undisclosed income of Rs.15,50,000/-.

The revenue then issued an acknowledgment in Form-2 dated 4th October 2016 requiring the petitioner to pay an amount of Rs.6,97,500/-. The petitioner, however, deposited an amount of Rs.3,48,752/- by way of two challans but could not deposi