Sabka Vishwas quantification requirement upheld: no valid declaration without pre-cutoff service tax liability being established.

Declarations under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 in the investigation, enquiry or audit category are limited to tax dues quantified on or before 30.06.2019. Quantification may arise from a written communication of duty payable or from a clear admission of liability by the declarant before the cut-off date. On the petitioner's own documents, the figures were expressly stated as not acceptable, and no clear admission or acknowledgment of service tax liability before 30.06.2019 was shown. The rejection of the declaration was therefore upheld.

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Issues: Whether the petitioner's declaration under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 was validly rejected on the ground that the service tax liability was not quantified on or before 30.06.2019.

Analysis: For declarations made in the category of investigation, enquiry or audit, tax dues are confined to duties quantified on or before 30.06.2019. Eligibility under the scheme is denied where the amount involved in the pending enquiry or investigation was not so quantified. Quantification includes a written communication of duty payable and also a duty liability admitted by the declarant during enquiry, investigation or audit. On the petitioner's own documents, the statement showing service tax/GST figures was accompanied by a note that the liability was not acceptable, and no clear admission or acknowledgment of liability before the cut-off date was established.

Conclusion: The rejection of the declaration was upheld, as there was no quantification of the service tax liability or admission of liability by the petitioner before 30.06.2019.

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