Legacy dispute relief under the Sabka Vishwas Scheme depends on balance tax dues, not voluntary payments already appropriated.

Under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, relief under section 124 is computed with reference to the relevant tax dues in the applicable category, and any pre-deposit or deposit already paid is deducted when the payable amount is quantified. The scheme is to be read on its own terms, and administrative circulars cannot dilute that framework. A voluntary payment already made towards tax liability and appropriated against the demand is not a pre-deposit made without prejudice while contesting liability, so it cannot be treated as a deductible deposit for enlarging the relief. On that basis, the committee's computation was upheld.

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Issues: Whether, under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, the relief payable under section 124 is to be computed on the entire tax liability or on the balance amount remaining after deduction of amounts already paid, and whether a voluntarily paid and appropriated amount can be treated as a pre-deposit or deposit for that purpose.

Analysis: The Scheme distinguishes between different categories of tax dues, including arrears, and section 124(2) requires deduction of pre-deposit or deposit already paid when the statement indicating the amount payable is issued. The relevant expression "tax dues" has to be read in context, and the statutory scheme cannot be diluted by administrative circulars. Relief is therefore computed on the tax dues falling within the relevant category, and the deduction of pre-deposit or deposit is to be made at the stage of quantifying the amount payable. However, the amount already paid by the petitioner had been voluntarily made towards the tax liability and had already been appropriated. Such payment was not a pre-deposit made without prejudice while contesting liability.

Conclusion: The calculation under the Scheme is to be made on the balance tax dues, but the petitioner's prior voluntary payment could not be treated as a deductible pre-deposit for enlarging the relief claimed. The committee's computation was upheld and the challenge failed.

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