What was the Direct Tax Vivad se Vishwas (DTVSV) 2024 scheme? DTVSV 2024, also called VSV 2.0, was a one-time dispute resolution scheme enacted under Chapter IV (Sections 88 to 99) of the Finance (No. 2) Act, 2024. It allowed taxpayers with pending income tax appeals, writ petitions, or special leave petitions as of 22 July 2024 to settle their disputes by paying a defined percentage of the disputed tax, interest, or penalty, in exchange for a complete waiver of the remaining interest and penalty and immunity from prosecution. The scheme opened on 1 October 2024 and closed permanently on 30 April 2025. No new declarations can be filed under DTVSV 2024 today.
Direct Tax Vivad se Vishwas 2024 Scheme: What It Offered, Who Used It, and What Happens Now
Nearly two years after the government first floated a second round of Vivad se Vishwas, the scheme has run its full course. DTVSV 2024 opened on 1 October 2024, gave taxpayers an early-bird window that was later extended, and shut its doors for good on 30 April 2025. For businesses and CAs who are only now assessing whether they missed an opportunity, or who filed a declaration and want to understand what happens next, this guide is a complete, retrospective walkthrough of the scheme.
We cover the legal basis, the settlement math with worked examples, who was excluded, how it compared to the original 2020 scheme, and what taxpayers who did file should expect as their Form 3 and Form 4 move through processing.
Legal Basis and Timeline
DTVSV 2024 was not a standalone Act. It was enacted as Chapter IV, comprising Sections 88 to 99, of the Finance (No. 2) Act, 2024, presented in the July 2024 Union Budget. The government notified the scheme's commencement date, the accompanying rules, and the prescribed forms in three separate steps over September 2024:
- Notification No. 103/2024 (19 September 2024): Notified 1 October 2024 as the date on which the DTVSV Scheme, 2024 came into force.
- Notification No. 104/2024, G.S.R. 584(E) (20 September 2024): Notified the Direct Tax Vivad se Vishwas Rules, 2024, along with Form-1, Form-2, Form-3, and Form-4.
- Circular No. 19/2024 (16 December 2024): Issued 35 FAQs from the CBDT clarifying eligibility, computation, and procedural questions raised by taxpayers and practitioners.
The scheme was designed around two payment tiers based on when a taxpayer filed their declaration. The original cutoff for the lower, "before" rate was 31 December 2024. The government extended this by one month via Circular No. 20/2024 (30 December 2024), pushing the early-bird deadline to 31 January 2025. The scheme itself remained open for late filers (at the higher rate) until the sunset date fixed by Notification S.O. 1650(E) (8 April 2025): 30 April 2025.
Deadline Timeline
DTVSV 2024 Key Dates
From enactment to sunset: the full lifecycle of the scheme
Finance (No. 2) Act, 2024 Passed
Chapter IV (Sections 88-99) enacts the DTVSV Scheme; eligibility cutoff set at disputes pending as of 22 July 2024
Commencement Notified
Notification 103/2024 fixes 1 October 2024 as the scheme's start date
Rules and Forms Notified
Notification 104/2024 (G.S.R. 584(E)) prescribes Form-1 to Form-4 and the Direct Tax Vivad se Vishwas Rules, 2024
Scheme Opens
Taxpayers can begin filing Form-1 declarations electronically on the income tax e-filing portal
CBDT Issues 35 FAQs
Circular 19/2024 clarifies eligibility, disputed tax computation, and procedural queries
Original Early-Bird Cutoff
Initial deadline for the lower settlement rate, before extension
Early-Bird Deadline Extended
Circular 20/2024 pushes the lower-rate cutoff to 31 January 2025
Extended Early-Bird Cutoff
Last date to file Form-1 at the lower (100%/110% or 25%/30%) settlement rate
Sunset Date Notified
Notification S.O. 1650(E) fixes 30 April 2025 as the scheme's closing date
Scheme Closes
Last date to file any DTVSV 2024 declaration; scheme now permanently closed to new filings
Source: Finance (No. 2) Act, 2024, Chapter IV; CBDT Notifications 103/2024, 104/2024; Circulars 19/2024, 20/2024; Notification S.O. 1650(E)
As of August 2026, the scheme is closed. There is no window left to file a fresh Form-1. What follows applies either as a historical reference or to taxpayers who already have a declaration in process.
Who Was Eligible
A taxpayer qualified under DTVSV 2024 if they had an income tax dispute pending as of 22 July 2024 before any of the following forums:
- Commissioner (Appeals) or Joint Commissioner (Appeals), CIT(A)/JCIT(A)
- Income Tax Appellate Tribunal (ITAT)
- High Court
- Supreme Court
Eligibility also extended to cases where an order had been passed but the limitation period to file an appeal had not expired as of 22 July 2024, and to disputes covered by a Dispute Resolution Panel (DRP) direction, revision applications under Section 264, and objections filed but not disposed of before a DRP.
The reference date of 22 July 2024 (Budget presentation day) is the anchor for the entire scheme. Any appeal, writ, or SLP that came into existence after that date, or any dispute already resolved before the taxpayer filed a declaration, fell outside the scheme's scope.
The Settlement Math: Four Rates, Two Cutoffs
The amount a taxpayer had to pay depended on two variables: whether they were classified as a "new appellant" or an "old appellant," and whether they filed their Form-1 on or before 31 January 2025 (the extended early-bird date) or after.
- Old Appellant: An appellant whose appeal, writ, or SLP was pending on or before 31 January 2020. This group had already had a chance to settle under the original DTVSV 2020 scheme and did not take it, or their dispute predates that window.
- New Appellant: An appellant who became an appellant only after 31 January 2020.
Disputed Tax Cases
| Category | Filed on or before 31 Jan 2025 | Filed after 31 Jan 2025 |
|---|---|---|
| New Appellant | 100% of disputed tax | 110% of disputed tax |
| Old Appellant | 110% of disputed tax | 120% of disputed tax |
Disputed Interest, Penalty, or Fee Only (No Disputed Tax)
| Category | Filed on or before 31 Jan 2025 | Filed after 31 Jan 2025 |
|---|---|---|
| New Appellant | 25% of disputed amount | 30% of disputed amount |
| Old Appellant | 30% of disputed amount | 35% of disputed amount |
A special concession applied where the taxpayer had already secured a favourable order from the ITAT or a High Court on the specific issue in dispute for the same assessment year, and the order had not been reversed by a higher forum. In that situation, the payable amount under the disputed tax table was reduced by 50%, recognising that the taxpayer already had strong legal ground.
Worked Examples
Example 1: New appellant settling a Rs 40 lakh disputed tax demand before the early-bird cutoff. A private limited company had a Rs 40 lakh addition confirmed at the assessment stage, appealed to CIT(A), and became an appellant in 2023 (making it a "new appellant"). It filed Form-1 on 15 January 2025, before the 31 January 2025 cutoff. Payable amount: 100% of Rs 40 lakh = Rs 40,00,000. All interest and penalty on this addition, which could easily have added another Rs 15 to 20 lakh if the case dragged on and was eventually lost, were waived entirely.
Example 2: Old appellant filing after the cutoff. An individual taxpayer had a Rs 12 lakh disputed tax demand pending at the ITAT since 2018 (an "old appellant" who had not settled under VSV 2020). They filed Form-1 on 20 March 2025, after the extended cutoff. Payable amount: 120% of Rs 12 lakh = Rs 14,40,000. Missing the 31 January 2025 date cost this taxpayer an extra Rs 1,20,000 compared to what they would have paid as an old appellant filing before the cutoff (110%, or Rs 13,20,000), and considerably more compared to what a new appellant would have paid.
Example 3: Penalty-only dispute with a favourable ITAT order. A firm was disputing a Rs 8 lakh penalty (no disputed tax remained, as the underlying tax addition had already been decided in the firm's favour by the ITAT for the same year, and that order had not been challenged further). As a new appellant filing before 31 January 2025, the base rate for a penalty-only dispute would have been 25% of Rs 8 lakh, or Rs 2 lakh. Because of the favourable, unreversed ITAT order, the firm qualified for the 50% reduction, bringing the payable amount down to Rs 1,00,000.
These examples illustrate the core trade-off: certainty and a lower cash outflow now, against the possibility (never a certainty) of winning the dispute outright and paying nothing, weighed against years of litigation, accruing interest, and legal costs in the interim.
What Was Excluded
DTVSV 2024 was narrower than its 2020 predecessor in one important respect. The following categories were excluded outright:
- Search and seizure cases under Sections 132 or 132A were completely excluded. This is a significant tightening: DTVSV 2020 had permitted search cases to be settled, subject to a cap where the disputed tax did not exceed Rs 5 crore. DTVSV 2024 removed this route entirely, regardless of the quantum involved.
- Cases involving undisclosed foreign income or foreign assets.
- Prosecutions or proceedings initiated under the COFEPOSA, UAPA, NDPS, or PMLA, or where prosecution had already been instituted and not compounded before the declaration was filed.
- Disputes relating to wealth tax, securities transaction tax (STT), or commodities transaction tax (CTT), since the scheme was limited to income tax disputes under the Income Tax Act.
- Cases where the dispute had already been resolved or withdrawn before the taxpayer filed their declaration.
Taxpayers with search-related additions, in particular, had no settlement route available to them under this iteration of the scheme, a point that generated considerable representation from industry bodies but was not reversed before the scheme closed.
The Filing Process: Form-1 to Form-4
Every declaration under DTVSV 2024 moved through a fixed four-form sequence, filed electronically on the income tax e-filing portal (incometax.gov.in).
Step-by-Step Guide
DTVSV 2024 Filing Sequence
From declaration to final settlement order
File Form-1 (Declaration)
Taxpayer files the declaration electronically, specifying the disputed tax, interest, or penalty amount and the applicable appellate forum. A separate Form-1 was required for each dispute or assessment year unless combined as permitted by the Rules.
TaxpayerDesignated Authority Issues Form-2
The Designated Authority (a jurisdictional Principal Commissioner or Commissioner nominated for this purpose) verifies the declaration and issues Form-2, a certificate confirming the amount payable and the particulars of the dispute.
Tax DepartmentTaxpayer Pays and Files Form-3
Within 15 days of receiving Form-2, the taxpayer pays the determined amount and intimates the payment details to the Designated Authority using Form-3.
TaxpayerDesignated Authority Issues Form-4
On confirming receipt of full payment, the Designated Authority issues Form-4, the final order recording full and final settlement of the dispute. Pending appeals, writs, or SLPs are treated as withdrawn.
Tax DepartmentThe Rules required a separate declaration for each assessment year in dispute, though certain combined filings were permitted where multiple years of the same taxpayer were before the same forum. Once Form-4 was issued, the settlement was final: the taxpayer could not reopen the same dispute, and the tax department could not raise it again for the same issue and year.
DTVSV 2024 vs DTVSV 2020: How the Two Schemes Compared
DTVSV 2024 was explicitly modelled on the 2020 scheme, but with a narrower scope and simpler rate structure.
Comparison
Direct Tax Vivad se Vishwas: 2024 vs 2020
| Parameter | DTVSV 2024 (VSV 2.0) | DTVSV 2020 |
|---|---|---|
| Legal basis | Finance (No. 2) Act, 2024, Chapter IV, Sections 88-99 | Direct Tax Vivad se Vishwas Act, 2020 (standalone Act) |
| Eligibility cutoff for pending disputes | Disputes pending as of 22 July 2024 | Disputes pending as of 31 January 2020 |
| Search and seizure (Section 132/132A) cases | Completely excluded, no exceptions | Allowed if disputed tax did not exceed Rs 5 crore |
| Settlement rate for disputed tax (before cutoff) | 100% (new appellant) or 110% (old appellant) | 100% (filed by 31 Mar 2020) or 110% (filed later) |
| Number of rate tiers | 4 tiers based on appellant type and filing date | Broadly 2 tiers based on filing date, plus search-case variant |
| Scheme duration | 1 Oct 2024 to 30 Apr 2025 (about 7 months) | 17 Mar 2020 to 31 Jan 2021 (about 10.5 months, extended multiple times due to COVID-19) |
| Reduction for favourable higher-court order | 50% reduction where ITAT/HC ruled favourably and order not reversed | Similar concept applied, with comparable reduction logic |
Takeaway: DTVSV 2024 kept the core disputed-tax settlement logic of the 2020 scheme but tightened eligibility by excluding all search cases and by penalising taxpayers who had already had one chance to settle in 2020 and did not take it.
The "old appellant" versus "new appellant" distinction is the most consequential structural difference. By charging old appellants a higher rate (110%/120% instead of 100%/110%), the government effectively signalled that taxpayers who declined the 2020 window and continued to litigate should not get the same terms as first-time settlers in 2024.
What If You Filed Under DTVSV 2024? Post-Declaration Processing
For taxpayers and CAs who did file a Form-1 before the scheme closed, the process does not end with payment. Here is what to expect as declarations move through the pipeline.
Form-2 discrepancies. Some taxpayers found that the Designated Authority's computation in Form-2 differed from what they had calculated in Form-1, typically because of disagreements over whether the "old appellant" or "new appellant" rate applied, or disputes about which portion of a demand was tax versus interest. Where this happened, taxpayers were expected to raise the discrepancy with the Designated Authority before making payment, since Form-3 payment is treated as acceptance of the Form-2 determination.
The 15-day payment window is firm. Once Form-2 is issued, the 15-day clock to pay and file Form-3 runs without much flexibility. Declarations where payment was delayed risked being treated as non-est (as if never filed), reviving the original appeal.
Form-4 finality. Once Form-4 is issued, the matter is closed permanently for that assessment year and issue. The corresponding appeal, writ petition, or SLP is treated as withdrawn, and neither side can reopen the point. Taxpayers should retain Form-4 as permanent proof of settlement, since it is the document that would be produced if the same issue is ever raised again in a different assessment year.
Backlog processing continues into 2026. Given the volume of declarations filed in the final weeks before the 30 April 2025 sunset, Designated Authorities across jurisdictions continued issuing Form-2 certificates and Form-4 orders well into late 2025 and into 2026. Taxpayers with declarations still pending a final Form-4 as of August 2026 should follow up with their jurisdictional Designated Authority rather than assume the matter has lapsed; the scheme's closure affected new filings only, not the processing of declarations already made before 30 April 2025.
No route to amend or withdraw after Form-3. Taxpayers who paid and filed Form-3 could not later withdraw from the scheme to revive litigation, even if a subsequent judicial development in a similar case might have favoured them. This is the trade-off inherent to any settlement scheme: certainty in exchange for giving up the upside of a favourable outcome elsewhere.
Lessons for the Next Amnesty Window
Direct tax amnesty schemes in India have followed a recognisable pattern: DTVSV 2020, the Vivad se Vishwas for indirect tax disputes under GST (introduced later), and now DTVSV 2024. A few takeaways are worth carrying forward for taxpayers evaluating any future scheme:
- Early filing consistently pays. In both the 2020 and 2024 schemes, the gap between the early-bird rate and the standard rate was material, often 10 percentage points on the disputed tax amount. On a large demand, that gap can run into several lakhs or more.
- Search cases are treated differently each time. DTVSV 2020 permitted limited search-case settlement; DTVSV 2024 excluded it entirely. Taxpayers with search-related disputes should not assume any future scheme will include them and should not delay other planning while waiting for one.
- "Old appellant" penalties are becoming a pattern. Taxpayers who sit out one amnesty window may find themselves paying a premium if a similar scheme is offered again later. Declining to settle is a legitimate strategic choice, but it is not without downstream cost if the government reintroduces a scheme with old-appellant surcharge pricing.
- Extensions happen, but late filing still costs more. The one-month extension of the early-bird cutoff (from 31 December 2024 to 31 January 2025) gave taxpayers extra runway, but did not change the higher post-cutoff rate for anyone who still missed the new date.
Frequently Asked Questions
Frequently Asked Questions
Is the Direct Tax Vivad se Vishwas 2024 scheme still open in 2026?
No. DTVSV 2024 closed permanently on 30 April 2025, the sunset date fixed by Notification S.O. 1650(E) dated 8 April 2025. No new Form-1 declarations can be filed. Only declarations filed before that date continue to be processed.
What was the difference between a new appellant and an old appellant under DTVSV 2024?
An old appellant is a taxpayer whose appeal, writ, or SLP was already pending on or before 31 January 2020, meaning they had a chance to settle under the original DTVSV 2020 scheme. A new appellant is someone who became an appellant only after 31 January 2020. Old appellants paid a higher settlement rate: 110% or 120% of disputed tax, compared to 100% or 110% for new appellants.
Were search and seizure cases eligible under DTVSV 2024?
No. Unlike DTVSV 2020, which allowed search cases to be settled where the disputed tax did not exceed Rs 5 crore, DTVSV 2024 excluded all cases arising from a search under Section 132 or a requisition under Section 132A, regardless of the amount involved.
What happens if I filed Form-1 under DTVSV 2024 but have not yet received Form-4?
Given the volume of filings before the 30 April 2025 sunset, many Designated Authorities are still processing declarations into 2026. If your Form-2 or Form-4 has not been issued, follow up directly with your jurisdictional Designated Authority. The scheme's closure to new filings does not affect the processing timeline for declarations already made.
Can I reopen a dispute after receiving Form-4 under DTVSV 2024?
No. Form-4 represents a full and final settlement. The underlying appeal, writ petition, or SLP is treated as withdrawn, and neither the taxpayer nor the tax department can reopen the same issue for that assessment year.
How did DTVSV 2024 treat cases where the taxpayer already had a favourable ITAT or High Court order?
Where a taxpayer had a favourable order from the ITAT or a High Court on the specific issue for the same assessment year, and that order had not been reversed by a higher forum, the amount payable under the disputed-tax table was reduced by 50%.
Where can I read the official rules and FAQs for DTVSV 2024?
The governing rules and forms are in Notification No. 104/2024 (G.S.R. 584(E)) dated 20 September 2024. The CBDT's detailed clarifications, covering 35 frequently raised questions, are in Circular No. 19/2024 dated 16 December 2024. Both are available on the Income Tax Department's official website.
Have an Unresolved Tax Dispute?
With DTVSV 2024 closed, taxpayers with pending assessments, appeals, or notices are back to evaluating the standard appellate route, or waiting to see whether a future amnesty scheme is introduced. Either way, the decision to settle, appeal, or litigate further depends on the strength of your case, the quantum involved, and how long you can afford to keep the matter open. Tax Garden's compliance team helps businesses and individuals assess pending disputes, respond to income tax notices, and plan for both current filings and any future settlement window. Get in touch for a consultation.
