SVLDRS eligibility in audit cases depends on written quantification before the cut-off date, not the final audit report.

Eligibility under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 turns on whether the declarant was subject to an enquiry, investigation or audit and whether the duty involved had not been quantified by 30 June 2019. Quantification was treated as a written communication of duty payable, including admission of liability during audit and audit reports, so the relevant date was not confined to the later final audit report. Because the audit material showed admission of liability and draft audit material had been prepared by June 2019, the rejection based only on the date of the final audit report was incorrect, and the declaration remained eligible under the scheme.

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Issues: Whether the petitioner was ineligible to make a declaration under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 on the ground that the amount of duty involved in the audit was not quantified on or before 30 June 2019.

Analysis: Eligibility under Section 125(1)(e) depends on two conditions being satisfied together: the declarant must have been subjected to an enquiry, investigation or audit, and the amount of duty involved must not have been quantified on or before the cut-off date. The scheme and the clarificatory notification and circular treat quantification as a written communication of duty payable, and include admission of liability during audit as well as audit reports within that expression. The audit material showed that the petitioner had admitted the liability under each objection and had agreed to pay the amounts. The relevant audit paras and the draft minutes were prepared by June 2019, and the later issuance of the final audit report did not govern the date of quantification. The rejection based only on the date of the final audit report was therefore incorrect.

Conclusion: The petitioner was not hit by Section 125(1)(e) and remained eligible under the scheme; the rejection of the declaration was unsustainable and the relief was in favour of the petitioner.

Ratio Decidendi: For SVLDRS eligibility, quantification of duty in an audit matter is satisfied when the liability is writtenly communicated or admitted before the cut-off date, and not merely when a later final audit report is issued.

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