Court directs respondents to accept petitioner's SVLDRS declaration, promoting fair tax dispute resolution.

The court ruled in favor of the petitioner, directing the respondents to consider the filed declaration valid under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 (SVLDRS). The court emphasized the petitioner's entitlement to file a consolidated declaration for all payable amounts, promoting fairness and efficiency in resolving tax disputes. The judgment aimed to minimize litigation and expedite the settlement of outstanding tax amounts, highlighting the unique circumstances of the case and disposing of the petition without costs.

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Issues:
Impugning Form No.3 under SVLDRS, calculation of tax amount payable under SVLDRS, treatment of fourth show cause notice, demand raised based on reference number, entitlement to file a consolidated declaration under SVLDRS, interpretation of SVLDRS scheme, minimizing tax disputes, considering the Application as filed, peculiar facts of the case.

Analysis:
The petitioner challenged Form No.3 issued by the designated committee under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 (SVLDRS), disputing the amount of Rs.38,41,637 imposed on them. The petitioner argued that no amount was payable, relying on Form SVLDRS-1 they had submitted. The core issue revolved around three show cause notices totaling Rs.1,15,39,463, which the respondents claimed fell under arrears as per SVLDRS, leading to a tax amount payable of Rs.65,18,031. A fourth show cause notice for Rs.76,83,273 was pending adjudication, with the respondents contending it should be treated as investigation, inquiry, or audit, resulting in an amount payable of Rs.38,41,637.

The petitioner faced a challenge as they had filed a single Application under SVLDRS for both categories, leading to a demand based on the reference number mentioned in the pending show cause notice. Despite the amounts falling under different categories, the court emphasized that a party could file a consolidated declaration for all payable amounts, ensuring fairness in payment. The SVLDRS scheme aimed to recover duty, tax, and arrears efficiently to minimize tax disputes and realize outstanding tax amounts in an exceptional manner, promoting settlement of disputed tax liabilities.

In light of the scheme's objective to reduce litigation and decide tax disputes, the court directed the respondents to consider the petitioner's filed declaration valid and process it according to the law. The judgment clarified that it was based on the unique circumstances of the case, ultimately disposing of the petition without any costs incurred.

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