Sabka Vishwas scheme eligibility turns on timely quantification of duty before the cut-off date, with fresh reconsideration required.

Under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, tax dues are eligible where the duty amount was quantified on or before 30.06.2019, and rejection is not justified merely because quantification was disputed if the record shows timely quantification. Here, the audit report showed quantification on 04.06.2019, and the revenue did not controvert it. The rejection of the declaration on the ground of non-quantification by the cut-off date was therefore unsustainable, and the application had to be reconsidered afresh in accordance with law.

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Issues: Whether the petitioner's declaration under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 was ineligible on the ground that the amount of duty had not been quantified on or before 30.06.2019.

Analysis: The Scheme permits tax dues where the amount payable under the indirect tax enactment has been quantified on or before 30.06.2019. Eligibility is excluded only where, after enquiry, investigation, or audit, the amount of duty involved had not been quantified by that date. The Audit Report produced on record showed quantification on 04.06.2019, and this was not controverted by the revenue.

Conclusion: The rejection of the declaration on the ground of non-quantification by 30.06.2019 was unsustainable, and the petitioner was entitled to reconsideration of the application afresh.

Final Conclusion: The impugned rejection was set aside and the matter was sent back for fresh consideration in accordance with law.

Ratio Decidendi: Where audit quantification of the duty involved is shown to have been made on or before 30.06.2019, the declaration cannot be rejected on the ground that the amount was not quantified within the statutory cut-off date.

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