( 1 ) ALL India Federation of Tax Practitioners, the petitioner, is a registered body having individual members from all over the country and also represents many associations having the object of protecting the interests of tax payers and tax consultants and to ensure that the direct tax laws are just and fair and are administered justly and fairly. The association is aggrieved by Kar Vivad Smadhan Scheme, 1998 and seeks to lay challenge to its constitutional validity.

( 2 ) KAR Vivad Samadhan Scheme, 1998 (hereinafter the Scheme, for short) is contained in Sections 86 to 98 of the Finance No. (2) Act, 1998. The object of the scheme as explained by the Finance Minister in his speech is:

"litigation has been the bane of both direct and indirect taxes. A lot of energy of the Revenue Department is being frittered in pursuing large number of litigations pending at different levels for long periods of time. Considerable revenue also gets locked up in such disputes. Declogging the system will not only incentivise honest tax-payers, enable Government to realise its reasonable dues much earlier but coupled with administrative measures, would also make the system more user-