Finality of amnesty settlements bars later claim to restore credit reversed to obtain closure of proceedings.

Acceptance of an amnesty scheme and closure of proceedings bars the assessee from later reopening the settlement on the claim that the credit reversal was mistaken. The text states that, after proceedings for breach of a customs exemption condition were dropped on the assessee's reversal of credit and payment of interest within the stipulated time, the settled position attained finality. A party cannot selectively resile from the basis on which relief was obtained or seek restoration of the very credit reversed to secure closure. The request for restoration was therefore rejected, and the concluded settlement remained binding.

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Issues: Whether an assessee who had accepted the benefit of an amnesty scheme and obtained closure of proceedings could later seek reversal of the very credit reversed before the authority on the plea that the reversal was mistaken.

Analysis: The appeal arose from a dispute under the customs exemption notification governing the import of inputs under the DEEC scheme. The assessee had been proceeded against for breach of a condition of the notification, but the proceedings were dropped after the assessee reversed the credit and paid interest within the time stipulated under the amnesty scheme. Having obtained relief on that basis, the assessee could not later contend that the facts placed before the Commissioner were incorrect and seek to retrieve the credit. A settlement accepted under an amnesty scheme attains finality and cannot be reopened selectively by the same party.

Conclusion: The request for restoration of credit was rejected, and the appeal failed.

Final Conclusion: Relief obtained under the amnesty scheme remained binding on the assessee, and the concluded settlement could not be re-agitated to claim a contrary benefit.

Ratio Decidendi: A party that secures closure of proceedings by accepting an amnesty scheme cannot subsequently resile from the basis on which the settlement was obtained or seek a contrary benefit from the same transaction.

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