Sabka Vishwas quantification and hearing requirements govern eligibility, making admitted duty liability and summary rejection legally unsustainable.

Duty liability admitted in a recorded statement and acknowledged by the department before 30.06.2019 was treated as quantified tax dues under the Sabka Vishwas scheme, making the declarant eligible in the investigation or enquiry category; rejection on non-quantification was therefore unjustified. The document also states that summary rejection of a declaration as ineligible, without notice or hearing, was inconsistent with the scheme and with natural justice because adverse civil consequences followed. On that basis, the declaration had to be reconsidered afresh after granting due hearing, and the impugned rejection could not stand.

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Issues: (i) Whether duty liability admitted in a statement and acknowledged by the department before 30.06.2019 amounted to quantified tax dues, making the declarant eligible under the investigation or enquiry category of the Sabka Vishwas scheme. (ii) Whether rejection of the declaration as ineligible without notice or hearing was valid.

Issue (i): Whether duty liability admitted in a statement and acknowledged by the department before 30.06.2019 amounted to quantified tax dues, making the declarant eligible under the investigation or enquiry category of the Sabka Vishwas scheme.

Analysis: The scheme treated cases under enquiry, investigation or audit as eligible where the duty involved had been quantified on or before 30.06.2019. Quantification included a written communication of the amount of duty payable, and the Board's circular also clarified that admission of duty liability in a statement would suffice. The declarant's proprietor had admitted the outstanding service tax liability in a recorded statement, and the department's subsequent communication referred to that admission. The amount of duty was therefore quantified within the meaning of the scheme before the cutoff date.

Conclusion: The declarant was eligible under the investigation or enquiry category, and the rejection on the ground of non-quantification was not justified.

Issue (ii): Whether rejection of the declaration as ineligible without notice or hearing was valid.

Analysis: The scheme itself contemplated a hearing where the Designated Committee proposed a higher payable amount than the amount declared. In that setting, outright rejection of a declaration on the ground of ineligibility without giving the declarant an opportunity to explain was held to be inconsistent with the object of the scheme and contrary to the principles of natural justice. Since rejection carried adverse civil consequences, notice and hearing were required before taking such a decision.

Conclusion: The rejection without affording an opportunity of hearing was invalid.

Final Conclusion: The declaration was required to be reconsidered afresh as a valid declaration under the scheme after granting due hearing, and the impugned rejection order could not stand.

Ratio Decidendi: For the Sabka Vishwas scheme, duty liability admitted by the declarant and acknowledged in writing by the department before 30.06.2019 constitutes quantification of tax dues, and a declaration cannot be summarily rejected as ineligible without affording the declarant a hearing where adverse civil consequences follow.

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