Court aligns paid amounts for relief calculation under Finance Act, 2019, quashes Form SVLDRS-3, emphasizes dispute resolution goals.

The Court aligned with the interpretation that all amounts paid during investigations should be considered for relief calculation under Section 124 of the Finance Act, 2019. It allowed the writ petition, quashed Form SVLDRS-3, and directed the Designated Committee to reconsider the claim by adjusting the amounts paid towards interest and penalty, emphasizing the scheme's amicable dispute resolution objectives. The decision aimed to achieve the scheme's beneficial goals by interpreting the legal provisions harmoniously, ensuring a fair resolution within a specified timeframe.

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Issues:
1. Interpretation of Section 124 of the Finance Act, 2019 regarding pre-deposit under the 'Sabka Vikas (Legacy Dispute Resolution) Scheme, 2019'.
2. Consideration of amount paid under protest towards interest before issuance of show cause notice as pre-deposit under the Scheme.

Analysis:
1. The petitioner sought a writ of certiorari to quash Form SVLDRS No. 3 issued by the respondents and requested a writ of mandamus to adjust the amount deposited. The key issue was whether the amount paid by the petitioner under protest towards interest before the show cause notice would be considered as a pre-deposit under the 'Sabka Vikas (Legacy Dispute Resolution) Scheme, 2019' under Section 124 of the Finance Act, 2019.

2. The petitioner argued that a similar issue was decided by the Punjab and Haryana High Court, where the pre-deposit included a penalty along with interest. The respondents raised technical issues regarding the expiration of the auto-populated forms. However, it was acknowledged that the scheme was initially till 31.03.2020, later extended to 30.06.2020.

3. Section 124(2) of the Finance Act, 2019 was crucial in this case. It mandated that any amount paid as pre-deposit during appeal proceedings or investigations should be deducted when issuing the statement of payable amount. The High Court of Punjab and Haryana emphasized that the provision did not differentiate between amounts paid under different heads, requiring deductions for any pre-deposit made during investigations, irrespective of the nature of the payment.

4. The Court aligned with the Punjab and Haryana High Court's interpretation, emphasizing the need to consider all amounts paid during investigations for relief calculation. The Court allowed the writ petition, quashed the comments of the Designated Committee, and directed a reconsideration of the claim by adjusting the amounts paid towards interest and penalty.

5. Despite technical objections, the Court viewed Section 124 as a benevolent provision aimed at resolving tax disputes amicably. The Court allowed the writ petition, quashed Form SVLDRS-3, and directed the Designated Committee to reconsider the claim after adjusting the amount paid towards interest, emphasizing the scheme's objectives.

6. The Court's decision was based on a harmonious interpretation of the Finance Act, 2019, to achieve the scheme's beneficial objectives. The writ petition was allowed, directing the Designated Committee to reconsider the claim after adjusting the amount paid towards interest within a specified timeframe.

7. In conclusion, the Court's judgment highlighted the importance of interpreting legal provisions in line with the scheme's objectives to facilitate amicable dispute resolution and avoid restrictive interpretations that hinder the scheme's purpose.

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