Sabka Vishwas relief cannot be denied for a technical form defect when audit records establish quantified tax dues.

Under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, a tax dues claim quantified in audit records on or before 30.06.2019 can attract the statutory relief where the substantive scheme conditions are met. A technical omission in Form SVLDRS-1, or an incorrect remark in Form SVLDRS-3, does not by itself defeat the accrued benefit when the Department's own records establish quantification and deposit details. The scheme requires verification on the basis of available records, and the declarant must not be denied relief for an apparent form error when entitlement is otherwise shown. The competent authority was directed to consider issuance of the discharge certificate.

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Issues: Whether the declarant was entitled to tax relief under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 on the basis of quantification made during audit before 30.06.2019, and whether the declaration could be rejected or the relief denied because of an in filling Form SVLDRS-1 and the resulting incorrect Form SVLDRS-3.

Analysis: The Scheme confers a substantive one-time tax relief where tax dues in an audit matter are quantified on or before 30.06.2019. Under the Scheme, tax dues are the quantified duty liability and tax relief is computed in terms of the prescribed percentage, with any pre-deposit or deposit required to be adjusted while issuing the amount payable. The audit note in the present matter quantified the liability and also recorded the deposit already made, and the declarant otherwise satisfied the Scheme conditions. The Department was required to verify the declaration on the basis of the records available with it, and a technical omission in the declaration form could not defeat the accrued statutory benefit when the underlying entitlement was established. The incorrect remark in Form SVLDRS-3 was also extraneous to the declarant's business and reflected an apparent error. The declarant was additionally deprived of the opportunity contemplated under the Scheme procedure.

Conclusion: The declarant was entitled to tax relief under the Scheme, and rejection on the basis of the error in Form SVLDRS-1 was not justified. The petitioner was entitled to have the competent authority consider issuance of the discharge certificate.

Final Conclusion: The writ petition was partly allowed and the Designated Committee was directed to consider issuance of the discharge certificate in accordance with the Scheme.

Ratio Decidendi: A statutorily quantified tax liability under the SVLDR Scheme cannot be denied on a mere technical defect in the declaration form when the substantive conditions for tax relief are otherwise satisfied and the Department's records establish the entitlement.

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