The pending number of tax litigation across various fora has reached an alarming stage. According to the finance minister, the total number of direct tax litigation pending across various authorities like commissioner of income tax (appeals), income tax appellate tribunals, high courts, and the Supreme Court have reached an astonishing number of 483,000 and more importantly, the number of new cases getting added to this is showing no signs of declining. This not only leads to discontent among taxpayers but also significantly increases the burden and associated costs for the government. Moreover, the government’s abysmal record of success in such