Legacy dispute resolution under Sabka Vishwas: admitted and communicated duty liability before the cut-off date satisfied quantification.

The Delhi HC treated "quantified" under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 as broadened by CBIC circulars and applied a liberal construction to legacy dispute resolution. Where audit proceedings were concluded before the cut-off date, the duty liability was communicated to the taxpayer, and the liability was admitted before 30 June 2019, the requirement of quantification was satisfied. On that basis, rejection of the declaration for alleged non-quantification was unsustainable.

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Issues: Whether the petitioner's case under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 was ineligible on the ground that the duty involved in the audit had not been quantified on or before 30 June 2019.

Analysis: The expression "quantified" in Section 121(r) of the Finance Act, 2019 was treated as having been broadened by the circulars issued by the Central Board of Indirect Taxes and Customs. The audit records showed that the audit was concluded on 28 June 2019, the duty liability was communicated to the petitioner, and the petitioner had admitted the liability before the cut-off date. The scheme and the circulars were held to require a liberal construction in order to resolve legacy disputes.

Conclusion: The duty liability stood admitted and quantified before the cut-off date, so the rejection of the declaration on the ground of non-quantification was unsustainable.

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