Section 106 - Person who may make declaration of tax dues

Voluntary tax declaration eligibility: limited where returns disclosed but unpaid; declarations rejectable if investigation or audit pending.

Section 106 permits voluntary declaration of service tax dues where no notice or order of determination was issued before the cut-off, but excludes persons who filed returns disclosing true liability yet failed to pay the disclosed amount, and bars declarations on an issue for subsequent periods if a notice or order was previously issued; declarations are subject to rejection by the designated authority where an inquiry, investigation (including search, summons, or production requirements) or an audit had been initiated and remained pending as of the cut-off.