Sabka Vishwas Scheme quantification can arise from a pre-cut-off written admission of liability, making the declaration maintainable.

Under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, a declaration in the enquiry, investigation or audit category is maintainable where tax dues were quantified on or before 30.06.2019. Quantification is satisfied by a written communication of the amount payable, including an admission of liability or a letter intimating duty demand; completed adjudication is not required before the cut-off date. A pre-cut-off letter admitting service tax liability therefore constituted sufficient quantification, and a later audit report did not change that position. The declaration was held maintainable, the rejection was unjustified, and the matter required fresh reconsideration.

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Issues: Whether the petitioner's declaration under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 was maintainable on the ground that the service tax dues were quantified on or before 30.06.2019, and whether the rejection of the declaration was justified.

Analysis: The scheme treated cases under enquiry, investigation or audit as eligible where the tax dues had been quantified on or before 30.06.2019, and quantified meant a written communication of the amount payable. Such written communication could include a letter intimating duty demand, an admission of liability by the declarant, or an audit report. The petitioner's letter dated 10.05.2019 contained a clear admission of service tax liability for the relevant period, which was prior to the cut-off date. The subsequent audit report only referred to that earlier admission and did not alter the fact that quantification had already occurred before 30.06.2019.

Conclusion: The declaration was maintainable and the rejection order was not justified. The petitioner's case fell within the eligible category under the Scheme, and the matter had to be reconsidered afresh.

Ratio Decidendi: For eligibility under the enquiry, investigation or audit category of the Scheme, quantification is satisfied by a pre-cut-off written communication admitting or intimating the duty liability, and it is not necessary that adjudication be completed before the cut-off date.

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