Prior written duty quantification under SVLDRS can bind the settlement process; rejection needs prescribed notice and hearing.

Under the Sabka Vishwas (Legacy Dispute Resolution Scheme), 2019, a prior written departmental communication can satisfy the requirement of "quantified" duty dues for a pending enquiry or investigation case. A later departmental computation does not automatically displace that earlier quantification, especially where part of the later demand is treated as time-barred or unenforceable. If the Department proposes a different amount from the declarant's figure, the Scheme requires issue of the prescribed form and a personal hearing before rejection. The text states that rejection without this procedure, and without reasons or an alternate enforceable demand, was unsustainable.

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Issues: Whether the petitioner's declaration under the Sabka Vishwas (Legacy Dispute Resolution Scheme), 2019 could be rejected on the basis of a later departmental quantification, and whether the rejection without issuing the prescribed form and hearing was sustainable.

Analysis: The declaration was founded on a prior departmental communication that constituted a written quantification of duty dues for the relevant period. Under the Scheme, "quantified" means a written communication of the amount of duty payable, and tax dues in pending enquiry or investigation cases are linked to such quantified amount. The later departmental computation was not a valid basis to displace the earlier quantification, particularly when even the Department stated that a substantial portion of the later demand was time-barred and had not been raised as an enforceable demand. Where the Department's estimate differs from the declarant's declaration, the Scheme requires issuance of the prescribed form with notice of personal hearing. That procedure was not followed, and the impugned rejection order contained no reasons or alternate demand.

Conclusion: The rejection of the declaration was unsustainable. The petitioner was entitled to have the declaration accepted on the basis of the earlier departmental quantification, and the matter had to be reconsidered by issuing the appropriate form afresh.

Final Conclusion: The declaration under the Scheme could not be rejected on an ad hoc or procedurally defective departmental reassessment, and the petitioner succeeded in obtaining acceptance of the settlement process.

Ratio Decidendi: Under the Sabka Vishwas (Legacy Dispute Resolution Scheme), 2019, a prior written communication of duty dues satisfies "quantification", and where the Department proposes a different amount, the prescribed notice and hearing procedure must be followed before rejecting the declaration.

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