Legacy dispute scheme: excess deposit with Revenue counts toward the 50% liability computation.

Under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, amounts already lying with the Revenue in excess of the appeal pre-deposit could be counted toward compliance with the liability computed at 50% of the disputed demand. The Court treated the additional sum in the Central Government treasury as money already deposited, capable of being accounted for whether paid as pre-deposit or as tax, and found no basis to exclude it from the scheme computation. The Revenue's challenge therefore failed, and the excess deposit was held adjustable for determining whether the assessee had satisfied the scheme liability.

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Issues: Whether, for the purpose of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, amounts already deposited with the Revenue in excess of the pre-deposit could be taken into account while determining whether the assessee had satisfied the liability computed at 50% of the disputed demand.

Analysis: The disputed service tax demand was quantified, and the amount required to be paid under the scheme was treated as 50% of that demand. The record showed that the assessee had already deposited a further sum with the Revenue, apart from the amount paid as pre-deposit in the appeal. The amount so lying with the Central Government treasury was held to be money already in deposit and capable of being accounted for, whether paid as pre-deposit or as tax. On that basis, the Court found no reason to exclude the additional deposit from consideration while examining compliance under the scheme.

Conclusion: The excess amount already deposited with the Revenue could be taken into account, and the challenge by the Revenue failed.

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