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Issues: Whether the petitioner was entitled to issuance of a discharge certificate under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 notwithstanding the error in the form and the pending de novo adjudication.
Analysis: The writ petition arose out of proceedings under Chapter V of the Finance Act, 2019 relating to the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019. The respondents ultimately accepted the petitioner's position that the tax liability had been wrongly reflected and that the petitioner was not required to pay the amount that had triggered the dispute. In view of this categorical stand, the Court treated the controversy as resolved in favour of the petitioner. The earlier interim concern regarding the remanded proceedings did not survive once the respondents conceded the petitioner's entitlement.
Conclusion: The petitioner was entitled to a discharge certificate and the writ petition was allowed.
Final Conclusion: The dispute under the legacy resolution scheme stood concluded in the petitioner's favour, and the competent authority was directed to issue the discharge certificate within the stipulated time.
Ratio Decidendi: Where the revenue accepts that the assessee is not liable to pay the disputed tax under the legacy dispute resolution scheme, the authority must issue the corresponding discharge certificate.
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