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Issues: Whether, under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, an amount paid in excess of the amount quantified as payable under voluntary disclosure is refundable.
Analysis: The declaration was filed under the voluntary disclosure category, in which the declarant is required to disclose and pay the full amount of tax dues. The record did not establish that the appellant had properly pursued or proved disagreement with the amount quantified by the designated committee, as the material showing the disagreement process was not produced. The statutory scheme treats the amount stated by the designated committee as the amount payable for settlement, and section 130 bars refund of amounts paid under the scheme, including any excess pre-deposit over the quantified amount. In this framework, the excess payment could not be treated as refundable merely because it exceeded the amount ultimately taken as payable for settlement.
Conclusion: The refund claim was not maintainable and the rejection of refund was correct.
Ratio Decidendi: Under the voluntary disclosure framework of the scheme, an excess payment made over the amount quantified as payable is not refundable where the declarant has not successfully established disagreement with the quantified dues and the statutory bar against refund applies.
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