Settlement of dispute under DTVSV Scheme is Impossible in Stage of Issuance of Notice u/s 148 of Income Tax Act: Patna HC

The Patna High Court held that settlement of disputes under the DTVSV Scheme cannot be pursued once a notice under Section 148 of the Income Tax Act is issued, as the scheme is only applicable at the pre-litigation stage. The court emphasized that taxpayers cannot opt for the scheme after reassessment proceedings have commenced, reinforcing the strict procedural timelines under tax laws. This judgment clarifies the limited window for availing the dispute resolution mechanism and prevents its misuse after enforcement actions begin.