Sabka Vishwas Scheme relief must account for actual tax deposits; formalistic denial cannot override the record.

Under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, the Designated Committee must verify the record and deduct actual tax already deposited before computing the relief payable. The Karnataka HC noted that the declarant had made an undisputed payment before the relevant date, while the later disputed demand arose from a different quantified liability. SVLDRS-2 and SVLDRS-3 issued by relying only on the amount shown in the appeal memorandum, without accounting for the recorded deposit, were therefore unsustainable. The declarant was entitled to have the actual payment considered and to receive the consequential discharge certificate.

---

---

Issues: Whether, under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, the Designated Committee was bound to consider the actual tax deposit made by the declarant and allow the corresponding tax relief, instead of confining itself to the amount reflected in the appeal memorandum and issuing SVLDRS-2 and SVLDRS-3 on that basis.

Analysis: The Scheme's tax relief mechanism requires deduction of amounts already deposited during enquiry, investigation, audit, or otherwise, and the Designated Committee is required under the scheme procedure to verify the records before finalising the statement payable by the declarant. The material on record showed that the petitioner had deposited an undisputed amount of tax before the relevant date, and the later demand under challenge in appeal related to a different quantified liability. The impugned forms proceeded on the premise that only the smaller amount mentioned in the appeal memorandum had been paid, without adequately accounting for the audit record and the later deposits. A declarant's entitlement to tax relief under the Scheme cannot be denied on a technical approach when the record discloses the larger undisputed deposit and the declarant is otherwise eligible.

Conclusion: The petitioner was entitled to the tax relief under the Scheme after taking into account the undisputed deposit, and the impugned SVLDRS-2 and SVLDRS-3 could not be sustained.

Final Conclusion: The declaration under the Scheme had to be processed by considering the actual tax already paid, and the declarant was to be granted the consequential discharge certificate on that basis.

Ratio Decidendi: Under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, actual tax already deposited and verifiable from the record must be deducted while computing tax relief, and such statutory relief cannot be refused on a technical or formalistic basis when the declarant is otherwise eligible.

---