Sabka Vishwas Scheme computation requires deduction of prior deposits before final quantification; defective Form SVLDRS-3 set aside.

Amounts already paid by a declarant as pre-deposit or deposit during enquiry, investigation, audit or appellate proceedings had to be deducted while computing the payable amount under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019. The Court held that Section 124(2) required proper adjustment of such sums before final quantification, and that the Designated Committee had not adequately considered the petitioner's case on the correct computation. Accordingly, Form SVLDRS-3 in its existing form was not sustainable, and the matter was remanded for fresh hearing and recomputation after the directed deposit.

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Issues: Whether the amount earlier paid by the declarant was required to be deducted while computing the amount payable under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, and whether the impugned Form SVLDRS-3 quantification could be sustained.

Analysis: The Scheme distinguished between the tax dues on which relief was to be computed and the amount already paid as pre-deposit or deposit during enquiry, investigation, audit or appellate proceedings. Section 124(2) mandated deduction of such amounts while issuing the statement indicating the amount payable by the declarant. The Court found that the Designated Committee had not properly considered the petitioner's case on the true application of these provisions and had proceeded to confirm the balance demand without adequate hearing on the computation. In these circumstances, the quantification in Form SVLDRS-3 could not be sustained in its existing form.

Conclusion: The impugned Form SVLDRS-3 was quashed and the matter was sent back for fresh hearing and recomputation after the petitioner deposits the directed amount; the petitioner thus obtained partial relief.

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