JUDGMENT :

MANMOHAN, J.

PRIMARY ISSUE

1. The primary issue that arises for consideration in the present case is whether an assessee is free to settle any appeal under the Direct Tax Vivad se Vishwas Act, 2020 (“DTVSV Act”) and is not required to settle all the pending appeals filed by the respondents-revenue for an assessment year.

RELEVANT FACTS

2. The relevant facts of the present case are that the Petitioner is a banking company incorporated under the laws of Japan and carries on the banking business in India through branches in various cities. The return of income filed by the petitioner was selected for scrutiny assessment and a final assessment order dated 29th October, 2010 under Section 143 read with Section 144C of the Income Tax Act, 1961 (for short ‘Act’) was passed by the Assessing Officer for the Assessment Year 2007-08 making various adjustments to the total income of the Petitioner.

3. The Petitioner challenged the assessment order by filing an appeal before the Tribunal which was disposed of vide order dated 19th September, 2014 deciding the various issues as under:

(a