Sabka Vishwas Scheme eligibility and pre-cut-off liability admission examined alongside hearing concerns and disputed communications.

The petition concerned eligibility under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, turning on whether the petitioner had admitted its service tax liability before the cut-off date. It also raised whether rejection of the claim was made without affording a personal hearing, and the significance of the petitioner's communication dated 26.03.2019 and the subsequent show cause notice issued in September 2019. The HC directed the matter to be listed on a later date and required the respondents to place the relevant communications on record for further consideration.

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Issues: (i) Whether the petitioner had admitted its service tax liability before the cut-off date so as to claim benefit under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019; (ii) Whether the petitioner was denied a personal hearing before rejection of its claim; (iii) What were the contents of the petitioner's communication dated 26.03.2019 and the subsequent show cause notice issued in September 2019.

Outcome: The matter was directed to be listed on a later date, and the respondents were asked to place the relevant communications on record for further consideration.

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