Vivad se Vishwas

Vivad se Vishwas (the Scheme) is an attempt by the Government of India (GoI) to put an end to pending direct tax disputes. The benefit under the Scheme is maximised if taxpayers avail it before 1 April 2020, though the Scheme is likely to be available till 30 June 2020. The Scheme is likely to cater to all the taxpayers having income tax disputes in India. Depending on the contours of the pending dispute, a proportion of the total tax, interest and penalty demanded, needs to be paid under the Scheme for settlement.

Interactive Webcast with the Principal CCIT, Mumbai on FAQs on 'Vivad se Vishwas' Scheme

Date and Time: Coming soon
Duration: 60 minutes

The recently launched dispute resolution scheme viz. The Direct Tax Vivad Se Vishwas Bill, 2020 (Scheme), has garnered a lot of attention amongst taxpayers and also aroused interest in relation to some open issues. In this regard, the Central Board of Direct Taxes vide its Circular No. 7 dated 4 March 2020, has released frequently asked questions (FAQs) covering answers to 55 Questions to provide clarity on various aspects on the Scheme.

After doing a multi-city panel discussion on the Scheme with Senior Tax Officials, PwC invites you to an interactive discussion over a webcast with a view to understand the key highlights from the FAQs, and discuss the open issues.

Click here to register for the webcast


Kamlesh Varshney
Joint Secretary, TPL (1),
Ministry of Finance, GoI

Sandeep Ladda
Corporate & International Tax, Global TMT Tax Leader
PwC India

In-depth Insights

Glimpses of the panel discussion: Vichaar on Vivad se Vishwas Scheme 2020

The scheme is for reducing litigation and we want to make the scheme a success. We are ready for making rectifications and order giving effect. Just as we are ready, taxpayers should also be ready to capitalise on the Scheme. Refunds will be given very fast and a clarification on timelines of granting of refund is expected. The Scheme is for reducing litigation and is qua the appeal and not the assessment year. One can approach under the Scheme only for a few appeals and not all the appeals of a particular assessment year. Clarification on refund of other years to be adjusted against demand for year under the Scheme is expected in FAQs.

Satish Kumar Gupta, Principal Chief Commissioner of Income Tax, Mumbai

The Scheme helps to resolve legacy Direct tax issues and allows the taxpayers to deploy time and resources in the conduct of business.

Geetha Ravichandran, Chief Commissioner of Income Tax, Mumbai

We cannot dissect a case and adjudicate on the merits of the case because that is not the intent of the Scheme.

Mahesh Shah, Chief Commissioner of Income Tax (International Taxation & Transfer Pricing), Mumbai

Rahul Garg, Partner, PwC, Tax & Regulatory, Pragya Sahay Saksena – Principal Chief Commissioner of Income Tax, International Taxation, Ashish Kumar – Commissioner of Income Tax, International Taxation, Dr. Prabha Kant – Commissioner of Income Tax, International Taxation.

Rupak Saha, Partner, PwC India

Ashutosh Chaturvedi, Partner, PwC India and Pragya Sahay Saksena – Principal Chief Commissioner of Income Tax

Gautam Mehra, Partner & Leader - Tax & Regulatory Services, PwC India addresses the gathering at the Vichaar on Vivad Se Vishwas Scheme event in Mumbai.

Satish Kumar Gupta, Principal Chief Commissioner of Income Tax, Mumbai, addresses the gathering at the Vichaar on Vivad Se Vishwas Scheme event in Mumbai.

Why should you consider it?

  • Brings certainty: Ends ambiguity around the likely outcome of disputes. 
  • Instant relief: The resolution process can be completed within a month, bringing an expeditious end to protracted disputes. 
  • Tangible savings: The Scheme provides for waiver of interest, penalty and prosecution. In disputes involving penalty, interest or fine, only partial amounts need to be paid. This will also have a bearing on the ongoing cost of litigation. 
  • Flexibility: The Scheme provides taxpayers with the option to choose the years of payment (even if the dispute is pending at the behest of the tax authorities), without creating a precedent. 
  • Focus on core activities: Frees the management from allocating time and resources towards ongoing disputes and allows organisations to focus on strategic business matters.

How PwC can help achieve the resolution

We will be present with you during the entire dispute resolution journey and provide complete handholding from strategy to execution. For any additional information about the Scheme, please reach out to your PwC relationship manager or write to



  • Simulating the likely outcome of tax disputes for enabling management to take considered calls (using our experience to gauge the efforts required for concluding disputes through existing mechanism) 
  • Evaluating the applicability of the scheme on different disputes (our regular engagement with revenue authorities helps in seeking clarifications in a timely manner, if required) 
  • Suggesting a way forward


  • Drafting requisite applications and computing amounts payable  
  • Liaising with revenue authorities to address queries and obtain confirmatory orders (our focused and dedicated efforts bring in efficiencies)
Post-implementation support

Post-implementation support

  • Reviewing the order for its conformity with the application

Contact us

Sanjay Tolia

Sanjay Tolia

Leader, Tax and Regulatory Services, PwC India

Tel: +91 22 6689 1321

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