Scheme eligibility depended on prior tax quantification, and unilateral disclosure by the assessee was insufficient.

Eligibility for Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 required quantification of service tax dues by the department before the cut-off date; a unilateral admission by the assessee was not enough, so the petitioner could not claim the Scheme benefit. The petitioner's letter only indicated liability during investigation and did not amount to departmental quantification, and the rejection of its declaration was therefore valid. No breach of natural justice arose because the petitioner did not seek a personal hearing and the rejection was based on the Scheme's automated process and the materials furnished by the petitioner.

---

---

Issues: Whether the petitioner was entitled to the benefit of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 in the absence of quantification of service tax liability on or before the cut-off date, and whether rejection of its declaration as a system-generated order without personal hearing vitiated the decision.

Analysis: Eligibility under the Scheme depended on prior quantification of the tax dues before 30.06.2019. A unilateral admission or disclosure by the assessee did not amount to quantification for the Scheme, since such an interpretation would defeat the statutory requirement and extend the benefit to cases where the department had not fixed the liability. The petitioner's letter only indicated liability during investigation and was not accepted or quantified by the department. The Court also noted that the petitioner had not sought a personal hearing, and the impugned rejection was based on the Scheme's automated process and the materials furnished by the petitioner. In these circumstances, no violation of natural justice was made out.

Conclusion: The petitioner was not eligible to claim the Scheme benefit, and the rejection of its declaration was upheld.

---