Departmental quantification requirement governs Sabka Vishwas eligibility; unilateral admission of liability is not enough.

Eligibility under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 depended on duty being quantified on or before 30 June 2019 in cases arising from enquiry or investigation. The term "quantified" was read to mean a written communication of the duty payable, and scheme circulars allowed a departmental letter or amount admitted during enquiry, investigation, or audit to qualify. A taxpayer's unilateral admission or self-computation, however, was not enough; the quantification had to be by the department. On that basis, a petitioner's letter admitting service tax liability did not satisfy the cut-off requirement, and rejection of the declaration was upheld. The challenge to the show cause notice was not entertained because statutory remedies were available.

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Issues: Whether the petitioner's unilateral communication admitting service tax liability constituted "quantification" for the purposes of eligibility under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019.

Analysis: The Scheme required, in cases arising from enquiry or investigation, that the amount of duty involved must have been quantified on or before 30 June 2019. "Quantified" was construed as a written communication of the amount of duty payable, and the circulars issued under the Scheme clarified that the expression could include a letter intimating duty demand or an amount admitted during enquiry, investigation, or audit. Even so, the decisive element was that the quantification had to be by the department and not merely a unilateral computation or admission by the taxpayer. The petitioner's letter of 18 June 2019 was only an admission of liability; it did not amount to departmental determination of the duty dues before the cut-off date.

Conclusion: The petitioner was not eligible under the Scheme, and the rejection of the declaration was upheld. The challenge to the show cause notice was also not entertained in view of the available statutory remedies.

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