Quantification under Sabka Vishwas includes a written admission of duty liability before the cut-off date, making the declaration eligible.

For the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, quantification in enquiry or investigation cases includes a written admission of duty liability made before the cut-off date, and final adjudicatory crystallisation is not required. The petitioner's proprietor admitted the service tax liability in a statement on 28.06.2019, which constituted quantification within the Scheme. A later letter merely repeated that admission and did not change the position. Rejection of the declaration solely because quantification was not final by 30.06.2019 was therefore inconsistent with the Scheme and departmental clarification, and the matter was remitted for reconsideration as a valid declaration under the enquiry or investigation category.

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Issues: Whether the petitioner's declaration under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 was valid where the service tax liability had been admitted in writing before 30.06.2019, and whether rejection of the declaration on the ground that quantification was not final by that date was sustainable.

Analysis: The eligibility condition for cases arising from enquiry, investigation or audit turns on whether the tax dues were quantified on or before 30.06.2019. Quantification, for the purpose of the Scheme, includes a written communication of the amount payable, including an admission of duty liability during investigation. The petitioner's proprietor recorded a statement on 28.06.2019 admitting the service tax liability for the relevant period. That admission preceded the cut-off date and constituted quantification within the meaning of the Scheme. A later letter only reiterated the earlier admission and did not alter the legal position. The rejection based solely on absence of final quantification by 30.06.2019 was therefore inconsistent with the Scheme and the departmental clarification.

Conclusion: The declaration could not be rejected on the ground that quantification was not final by 30.06.2019; the petitioner's admission before the cut-off date made the declaration eligible for consideration under the Scheme.

Final Conclusion: The rejection order was set aside and the matter was remitted for reconsideration of the declaration as a valid application under the enquiry or investigation category with consequential relief after hearing.

Ratio Decidendi: For purposes of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, "quantified" includes a written admission of duty liability made during enquiry or investigation before the cut-off date, and final adjudicatory crystallisation is not required.

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