Sabka Vishwas Scheme eligibility turns on full quantification of tax dues; partial admission cannot support piecemeal settlement of a composite demand.

Eligibility under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 depended on tax dues being quantified in writing on or before the relevant date in investigation cases. An admission of Service Tax liability during inquiry could amount to quantification only of that admitted component, not of the entire demand covered by a later show cause notice. The Scheme also did not permit fragmented settlement of one part of a composite investigation demand through separate discharge certificates. The rejection of the declaration was therefore upheld.

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Issues: Whether the petitioner's declaration under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 was eligible on the basis that the Service Tax liability admitted during investigation constituted quantified tax dues on or before 30 June 2019, and whether the Scheme permitted settlement of only one admitted component of a larger demand.

Analysis: Eligibility under the Scheme depended on the existence of "tax dues" quantified on or before the relevant date in cases involving enquiry, investigation, or audit. The statutory scheme linked eligibility under Section 125(1)(e) to the definition of "tax dues" in Section 123(c), while "quantified" meant a written communication of the amount payable under Section 121(r). The Court noted the clarificatory circulars relied upon by the petitioner, including the clarification that an admitted liability during enquiry, investigation, or audit could amount to quantification. However, the Court held that the petitioner's admission related only to one component, namely Service Tax, and did not amount to quantification of the entire tax dues covered by the later show cause notice. The Court further held that the Scheme did not contemplate fragmented settlement of one part of a composite investigation demand. The discharge certificate mechanism under Section 129 could not be used to split the same matter and same time period into separate settlements, particularly where the investigation was ongoing on the relevant date and the show cause notice arose from the same investigation.

Conclusion: The petitioner was not eligible for relief under the Scheme on the footing urged, and the rejection of the declaration was upheld.

Ratio Decidendi: For purposes of the Scheme, an admission of one component of liability during investigation does not amount to quantification of the entire tax dues, and the Scheme does not permit piecemeal or fragmented settlement of a composite demand arising from the same investigation.

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