Single declaration under Sabka Vishwas Scheme accepted for one consolidated appeal arising from multiple show cause notices.

A single declaration under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 was held sufficient where one consolidated appeal arose from one common adjudication order covering multiple show cause notices. Rule 3(2) was construed with the definition of a "case" and the Scheme's object of reducing litigation, while Rule 6A of the CESTAT (Procedure) Rules, 1982 supported maintainability of one appeal against one order. Filing separate declarations was treated as procedural, not a substantive eligibility requirement, and a hyper-technical objection could not defeat relief when the statutory conditions were otherwise met and no prejudice to Revenue was shown. The rejection was set aside and discharge certificate issuance directed on compliance with remaining conditions.

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Issues: Whether a single declaration under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 could be filed in respect of a consolidated appeal arising from multiple show cause notices decided by one common adjudication order, and whether rejection of the declaration on the ground that separate declarations were required was justified.

Analysis: The pending matter before the Tribunal was a single appeal arising from one consolidated order, even though that order related to more than one show cause notice. Rule 3(2) of the Scheme was read in light of the definition of a "case" and the scheme's object of reducing litigation and realising revenue without unnecessary disputes. Rule 6A of the CESTAT (Procedure) Rules, 1982 was also relied upon to show that one appeal is maintainable against one order notwithstanding multiple show cause notices. The filing of declarations under the Scheme was treated as a procedural step, not a substantive eligibility condition, and the Court held that a hyper-technical insistence on multiple declarations could not defeat the benefit where the petitioner satisfied the statutory eligibility requirements and no prejudice to the Revenue was shown. The principle that the singular includes the plural under Section 13(2) of the General Clauses Act, 1897 further supported acceptance of one declaration for the consolidated appeal.

Conclusion: The rejection of the declaration on the ground that separate declarations were not filed for each show cause notice was not sustainable, and the petitioners were entitled to have their declaration considered under the Scheme.

Final Conclusion: The petitions succeeded, the impugned rejection orders were set aside, and the respondents were directed to issue the discharge certificate upon compliance with the remaining statutory conditions.

Ratio Decidendi: Where multiple show cause notices culminate in one consolidated order and one appeal is pending, the requirement of filing declarations under a beneficial dispute-resolution scheme must be construed so as not to defeat substantive entitlement on a mere procedural or hyper-technical objection, especially when no prejudice to the Revenue is shown.

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