Vivad Se Vishwas Scheme: A Principled Debate on Tax Amnesties

11 Pages Posted: 19 Apr 2021

See all articles by Shambhavi Sharma

Shambhavi Sharma

Tamil Nadu National Law University

Date Written: March 29, 2021


Resolution-cum-amnesty scheme may generate revenue in the short run, by including delinquent taxpayers and those with pending disputes. But, in the long run, several critics have mentioned it as a disincentivizing scheme for citizens who are complying with the law. Further, in the absence of a provision to the effect, the non-severability of issues in a single appeal could lead to adverse consequences for an individual opting for the scheme. Other fall-outs of the scheme could be issues with its interpretation.

Therefore, this paper shall address issues ranging from the very basic idea of tax as a the contract between the state and its citizens and how such schemes negatively impact this contract, ultimately creating a tax ecosystem that disincentivises compliance. To issues with the implementation of such scheme and where it stands on the merits of its aims and objects sought to be achieved, concluded by a factual assessment of reduction in pending litigations.

Keywords: direct tax, tax amnesty, vivad se vishwas, tax jurisprudence

Suggested Citation

Sharma, Shambhavi, Vivad Se Vishwas Scheme: A Principled Debate on Tax Amnesties (March 29, 2021). Available at SSRN: or

Shambhavi Sharma (Contact Author)

Tamil Nadu National Law University ( email )

Dindugal Main Road
Trichy, Tamil Nadu 620027

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