Sabka Vishwas eligibility turns on pre-cut-off quantification of duty liability; later show cause notice does not bar Form-3.

Duty liability quantified during inquiry or investigation before the cut-off date satisfied the Scheme's eligibility condition, and the later issue of a show cause notice did not disqualify the declarants. The Court held that an admitted liability reflected in a reconciliation statement and recorded statement amounted to quantification for purposes of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019. The petitioners were therefore eligible to declare under the Scheme and were entitled to issuance of Form-3 for payment of the balance amount.

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Issues: Whether the petitioners were ineligible under Section 125(1)(e) of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 on the ground that the duty amount had not been quantified on or before 30 June 2019, and whether they were entitled to issuance of Form-3 under the Scheme.

Analysis: The amount of duty payable had been quantified before 30 June 2019 through the reconciliation statement and the statement recorded during investigation, in which liability was admitted. The subsequent issuance of a show cause notice after 30 June 2019 did not by itself disqualify the petitioners, because the statutory requirement was only that the duty involved in the inquiry or investigation be quantified on or before the cut-off date. The Scheme's definition of quantified, as explained in the notified clarification, includes admitted duty liability during inquiry or investigation.

Conclusion: The petitioners were eligible to make a declaration under the Scheme and were entitled to issuance of Form-3 for payment of the balance amount.

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