Departmental quantification is mandatory for Legacy Dispute Resolution Scheme relief; unilateral liability admission is insufficient.

Eligibility under the Sabka Vikas (Legacy Dispute Resolution) Scheme, 2019 in enquiry, investigation or audit cases depends on departmental quantification of the duty payable on or before the statutory cut-off date. Quantified means a written communication by the Revenue specifying the amount due; a unilateral admission of liability by the assessee does not meet that requirement. On the facts described, the material showed only self-admitted liability and no departmental quantification, so the rejection of the scheme application was legally justified.

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Issues: Whether the petitioner was entitled to invoke the Sabka Vikas (Legacy Dispute Resolution) Scheme, 2019 on the basis of a letter containing only a unilateral admission of duty and tax liability, or whether eligibility required quantification of the amount by the Department on or before the statutory cut-off date.

Analysis: The Scheme requires, in cases of enquiry, investigation or audit, that the amount of duty payable be quantified on or before the relevant date. "Quantified" means a written communication of the amount of duty payable under the indirect tax enactment. The benefit of the Scheme is available only where the Department has determined and communicated the amount, and not where the assessee merely admits liability in a statement or communication. A unilateral declaration by the assessee does not satisfy the statutory requirement of quantification. The material relied upon by the petitioner disclosed only an admission of liability and not a departmental quantification of demand.

Conclusion: The petitioner was not eligible under the Scheme, and the rejection of the application was in law and calls for no interference.

Final Conclusion: The writ petition failed because the asserted liability was only self-admitted and was not a quantified demand communicated by the Revenue within the statutory framework of the Scheme.

Ratio Decidendi: For eligibility under the Sabka Vikas (Legacy Dispute Resolution) Scheme, 2019 in enquiry or investigation cases, quantification must be a departmental written communication of duty payable before the cut-off date; a unilateral admission by the assessee is insufficient.

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