Interest-only claims under Sabka Vishwas scheme may fall within tax dues, requiring reconsideration of rejected declarations.

A declaration under the Sabka Vishwas Legacy Dispute Resolution Scheme, 2019, based only on an interest demand after full payment of tax dues, was treated as falling within the scheme's "tax dues" coverage in light of the Board's instruction dated 06.10.2022. The instruction clarified that such cases are eligible for waiver of interest, so a rejection on the ground that the claim did not relate to tax dues could not be sustained. The rejection was quashed and the matter was sent back for fresh consideration by the designated committee in accordance with the clarified position.

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Issues: Whether a declaration under the Sabka Vishwas Legacy Dispute Resolution Scheme, 2019, based only on interest demand, could be rejected on the footing that it did not relate to tax dues, and whether the rejection order deserved interference.

Analysis: The declaration was declined on the premise that the claim related only to interest and not to tax dues. The Board's instruction dated 06.10.2022 clarified that, for the scheme, cases where tax dues have already been paid in full but interest has been demanded in a show cause notice or order-in-original are eligible for waiver of interest. The instruction further clarified that such cases fall within the scheme's expression "Tax Dues". In light of this clarification, the rejection of the petitioner's claim could not stand and the matter required fresh consideration by the designated committee.

Conclusion: The rejection of the petitioner's declaration was unsustainable and was quashed, with a direction to reconsider the claim in accordance with the Board's instructions.

Final Conclusion: The petitioner obtained relief against the impugned rejection, and the matter was sent back for reconsideration under the scheme on the clarified legal position.

Ratio Decidendi: Where the competent tax authority clarifies that a scheme covering tax dues extends to cases involving only interest demand after payment of tax dues in full, a rejection treating such a claim as outside the scheme cannot be sustained.

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