The scheme excludes matters initiated after the statutory cut-offs and treats each SCN as a whole, disallowing issue wise selection; deposits already made are deductible in computing the net payable, with CENVAT credit generally regarded as eligible for offset though future payments must be in cash. Personal penalties are eligible but may require separate applications; treatment of co noticees, payments made prior to notices, and interactions between voluntary declaration and amounts in arrears remain areas of divergent panel views and require formal clarification. (AI Summary)
TaxTMI