Sabka Vishwas voluntary disclosure requires credit for prior payments before computing outstanding tax dues.

In voluntary disclosure under the Sabka Vishwas scheme, "tax dues" were read to mean only the outstanding duty remaining after crediting amounts already paid before the scheme commenced. The Court rejected a construction that would treat discharged liability as still payable, holding that such an approach would be unreasonable and would permit collection without authority of law. It further held that the designated committee had to take the petitioner's pre-deposits into account and issue a fresh SVLDRS-3 statement. The impugned statement was set aside and the matter remitted for redetermination after giving credit for prior payments.

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Issues: (i) Whether, in a voluntary disclosure declaration under the Sabka Vishwas scheme, the expression "total amount of duty stated in the declaration" includes only the outstanding tax liability after giving credit for amounts already paid before the scheme came into force. (ii) Whether the designated committee was required to take into account the petitioner's pre-deposits and issue a fresh statement accordingly.

Issue (i): Whether, in a voluntary disclosure declaration under the Sabka Vishwas scheme, the expression "total amount of duty stated in the declaration" includes only the outstanding tax liability after giving credit for amounts already paid before the scheme came into force.

Analysis: The statutory scheme defines "tax dues" for voluntary disclosure as the total amount of duty stated in the declaration, and the Court read this expression in its context and object. It held that "tax dues" denotes what remains owing and payable, not amounts already discharged before the scheme's commencement. A literal construction that ignored prior payments would produce an unjust and unreasonable result and would permit recovery of tax without authority of law. The scheme was treated as beneficial legislation intended to encourage settlement, and its provisions were read to avoid absurdity and unfairness. The Court also held that the no-verification proviso for voluntary disclosure did not justify treating already-paid amounts as still payable.

Conclusion: The expression "total amount of duty" in the voluntary disclosure category means the outstanding duty after adjusting amounts already paid; the contention of the revenue was rejected.

Issue (ii): Whether the designated committee was required to take into account the petitioner's pre-deposits and issue a fresh statement accordingly.

Analysis: The petitioner had disclosed the pre-deposits in its declaration and supporting communications, and the dispute was only about their treatment in the estimated statement. Since the scheme could not be applied to require payment of amounts already discharged, the impugned statement was erroneous to the extent it ignored the pre-deposits. The appropriate course was to quash that statement and direct a fresh determination after giving credit for the deposits already made.

Conclusion: The designated committee was required to factor in the petitioner's pre-deposits and issue a fresh SVLDRS-3 statement.

Final Conclusion: The writ petition succeeded, the impugned statement was set aside, and the matter was remitted for a fresh statement after giving credit for the petitioner's prior payments.

Ratio Decidendi: In a voluntary disclosure under the Sabka Vishwas scheme, "tax dues" mean the unpaid balance of duty remaining after adjustment of amounts already discharged, because the scheme cannot be construed to authorise collection of tax already paid.

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