Sabka Vishwas Scheme relief depends on category eligibility, with voluntary disclosure available despite form objections.

The Arrears Category under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 was unavailable because the tax dues had not been assessed and adjudication remained pending. The Scheme, being beneficial legislation, was to be construed liberally to advance its object. On the material before the Court, the Revenue ed that the petitioners could instead proceed under the Voluntary Disclosure Category and assured consideration of the application despite objections arising from the form or particular columns. The claimed statutory block was therefore not sustainable, and the claim was to be processed under the Voluntary Disclosure Category in accordance with law.

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Issues: Whether the petitioners were entitled to be treated as eligible under the Arrears Category of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, and whether they could be directed to have their claim considered under the Voluntary Disclosure Category.

Analysis: The claim for the Arrears Category was not sustainable because the tax dues had not yet been assessed and adjudication was still pending. At the same time, the Scheme being a beneficial statutory scheme required a liberal construction to advance its object. On the material placed before the Court, the Revenue accepted that the petitioners were not entitled to the Arrears Category but could opt for the Voluntary Disclosure Category, and also assured that the application would be considered on that basis notwithstanding objections arising from the form or certain columns in it. The apprehension of rejection on a statutory block was therefore not well founded.

Conclusion: The petitioners were not entitled to the Arrears Category, but they were entitled to consideration of their claim under the Voluntary Disclosure Category, and the Revenue was directed to process such claim in accordance with law.

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