Beneficial dispute-resolution scheme: accepted adjudicated demand, not original notice amount, governs computation of tax dues.

For the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, "tax dues" were held to be the reduced amount quantified in the adjudication order that had been accepted by the department, not the higher amount stated in the original show cause-cum-demand notice. The scheme was treated as a beneficial amnesty measure requiring liberal construction to advance settlement of legacy excise disputes. The court applied the principle against reformatio in peius and held that a declarant could not be placed in a worse position merely because the adjudication order was later set aside and remanded in appellate proceedings. The accepted quantified demand remained the operative basis for computation.

---

---

Issues: Whether, for purposes of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, the "tax dues" of the declarants were to be taken as the original amounts stated in the show cause-cum-demand notice or as the reduced amounts quantified in the later order in original which had been accepted by the department.

Analysis: The scheme is a beneficial amnesty measure intended to resolve legacy excise disputes, and its provisions must be interpreted liberally to advance that object. The show cause notice had culminated in an adjudication order that substantially reduced the demand, and that reduced quantification was accepted by the department. Although the appellate tribunal later set aside that order and remanded the matter for a fresh decision on all issues, the Court held that the declarants could not be placed in a worse position merely because they had pursued appellate remedies or sought the benefit of the scheme. The principle against reformatio in peius applied, and the accepted quantified demand in the order in original remained the relevant measure of tax dues.

Conclusion: The tax dues were to be computed on the reduced amounts determined in the order in original, not on the higher amounts in the show cause-cum-demand notice.

Ratio Decidendi: Under a beneficial dispute-resolution scheme, where an adjudicated demand has been accepted by the department, the declarant cannot be made worse off by subsequent appellate remand so as to revive the higher original notice amount as the tax dues.

---