Accepted quantification by the cut-off date is essential for Sabka Vishwas scheme eligibility in audit-linked disputes.

Eligibility under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 depends on the dispute falling within the statutory category and on accepted quantification of the duty or tax dues by the cut-off date. In disputes arising from enquiry, investigation or audit, the scheme does not extend to unquantified liability; provisional or intermediary departmental communications requiring revision of worksheets do not amount to final quantification. Where the demand was not shown to have been duly quantified on or before 30 June 2019, the declarant remains excluded from relief under the scheme and must pursue the alternate statutory remedy.

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Issues: (i) whether the petitioner was eligible to make a declaration under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 in respect of a dispute arising from an enquiry, investigation or audit; (ii) whether the demand had been quantified on or before 30 June 2019 so as to attract the scheme.

Issue (i): whether the petitioner was eligible to make a declaration under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 in respect of a dispute arising from an enquiry, investigation or audit.

Analysis: Eligibility under the scheme depends upon the declarant falling within the statutory categories and not being hit by the exclusion in the provision dealing with persons subjected to enquiry, investigation or audit where the duty involved has not been quantified by the cut-off date. The scheme is intended to settle quantified legacy disputes and not cases where liability remained unquantified when the declaration was filed.

Conclusion: The petitioner was not eligible to invoke the scheme on the facts found.

Issue (ii): whether the demand had been quantified on or before 30 June 2019 so as to attract the scheme.

Analysis: The Court treated the departmental communications as only provisional or intermediary steps calling for revision of worksheets and further reversal, and not as a final acceptance or quantification of the duty liability by the department before the cut-off date. In the absence of accepted quantification on or before 30 June 2019, the statutory condition for relief under the scheme was not satisfied.

Conclusion: The demand was not shown to have been duly quantified by the relevant date.

Final Conclusion: The challenge to the rejection under the settlement scheme failed, and the writ petition was not maintainable for relief under the scheme. The petitioner was left to pursue the alternate statutory appellate remedy.

Ratio Decidendi: For a dispute linked to enquiry, investigation or audit, accepted quantification of duty or tax dues on or before the statutory cut-off date is a sine qua non for eligibility under the settlement scheme; without such quantification, the declarant is excluded from relief.

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