ORDER :

(Sushrut Arvind Dharmadhikari, J.) :

Heard finally with the consent of both the parties.

In the present writ petition under Article 226 of the Constitution of India the petitioner seeks to challenge the orders dated 31.03.2021 as also the order dated 15.04.2021 passed by the Designated Authority (Respondent No.1) under the Direct Tax Vivaad se Vishwas Act, 2020 (hereinafter referred to as “DTVSV Act, 2020 or 'Scheme') whereby the said authority has rejected the declaration filed by the deceased assessee Smt. Sumitra Raje Dalvi on the ground that the condition regarding pendency of appeal as on 31.01.2020 is not satisfied.

2. The brief facts of the case are that the petitioner is the son of Smt. Sumitra Raje Dalvi and the same has been filed in the capacity as her legal heir. The deceased mother was a regular income tax assessee and was filing her income tax returns regularly. The present matter relates to Assessment Year 2012-13 relevant to Financial Year 2011-12 in respect of which an order under Section 143(3) r/w Section 147 of the Income Tax Act, 1961 (hereinafter referred to as the “Income Tax Act”) was passed by the Income Tax Officer – 2(3), Indore vide her order dated 2