Prior written quantification under the legacy scheme preserved eligibility, and summary rejection without hearing breached natural justice.

Under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, tax dues were treated as quantified where the amount payable had been communicated in writing before 30 June 2019, and the declarant's written admission for another period also satisfied the cutoff requirement. A discrepancy in the electronic declaration was only a curable error and did not defeat eligibility for the enquiry or investigation category. Rejection of the declaration without affording a hearing was contrary to the scheme and natural justice because the decision carried adverse civil consequences. The declaration was therefore to be reconsidered afresh after hearing the declarant and by a speaking order.

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Issues: (i) Whether the declarant's tax dues under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 were quantified on or before 30 June 2019 so as to make the declaration under the enquiry or investigation category eligible. (ii) Whether rejection of the declaration without granting an opportunity of hearing was legally sustainable.

Issue (i): Whether the declarant's tax dues under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 were quantified on or before 30 June 2019 so as to make the declaration under the enquiry or investigation category eligible.

Analysis: Under the scheme, a person subjected to enquiry, investigation or audit is eligible only if the amount of duty involved has been quantified on or before 30 June 2019. "Quantified" means a written communication of the amount of duty payable. The written communication issued by the department for one period and the declarant's written admission for the other period, both before the cutoff date, satisfied the statutory requirement. The discrepancy in the amount declared in the electronic form was held to be a curable error and did not alter the basic eligibility position.

Conclusion: The tax dues were quantified on or before 30 June 2019 and the declaration was eligible.

Issue (ii): Whether rejection of the declaration without granting an opportunity of hearing was legally sustainable.

Analysis: The scheme itself contemplates a hearing where the Designated Committee proposes an amount higher than the amount declared. A summary rejection on the ground of ineligibility, without hearing the declarant, was held to be contrary to the scheme's objective and to the principles of natural justice. The rejection also carried adverse civil consequences, which reinforced the need for notice and hearing. The scheme was further required to receive a liberal construction as a one-time legacy dispute resolution measure.

Conclusion: Rejection without hearing was not sustainable and was liable to be quashed.

Final Conclusion: The declaration had to be reconsidered afresh by the Designated Committee after giving the petitioner an opportunity of hearing and by passing a speaking order.

Ratio Decidendi: Where the statutory conditions of the legacy scheme are satisfied by prior written quantification of tax dues, a declarant cannot be denied the scheme's benefit by a mechanical rejection, and any adverse rejection affecting civil consequences must comply with natural justice.

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