Prior quantification under Sabka Vishwas Scheme must be shown before the cut-off date to sustain declaration eligibility.

Eligibility under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 depended on whether the tax liability had been quantified before 30.06.2019. The Court examined whether pre-show-cause communications and the offence report amounted to quantification under Section 121(r), but found that the declaration in Form SVLDRS-1 itself treated the later show cause notice as the source of the demand. On that material, prior quantification was not established, and the rejection of the declaration could not be disturbed. The writ challenge therefore failed, with no entitlement to relief under the Scheme.

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Issues: Whether the petitioner's liability was quantified before 30.06.2019 so as to make the declaration under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 maintainable.

Analysis: The relevant question was whether the communications and offence report preceding the show cause notice amounted to quantification within the meaning of Section 121(r) of the Scheme. The declaration filed in Form SVLDRS-1 itself mentioned the demand figure as arising from the later show cause notice, which indicated that the petitioner did not treat the earlier reminder as the operative quantification. The rejection could not be faulted on grounds different from those recorded in the impugned order, and on the material placed the Court was not satisfied that the liability had been quantified by the cut-off date.

Conclusion: The petitioner was not entitled to relief under the Scheme on the ground of prior quantification.

Final Conclusion: The challenge to rejection of the declaration failed, and the writ petition did not warrant interference.

Ratio Decidendi: For availing relief under the Scheme, quantification of the tax liability must be shown to have occurred before the prescribed cut-off date, and the declaration must itself be consistent with that asserted prior quantification.

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