Quantified duty under the Sabka Vishwas Scheme can arise from the assessee's own written admission before the cut-off date.

For Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, "quantified" duty means a written communication of duty payable on record before 30.06.2019, and it need not originate only from the department. Where the assessee itself furnished written statements and calculation sheets admitting the duty liability during enquiry or investigation, and the department did not dispute that computation, the liability was treated as quantified within the statutory definition. The later issue of a show cause notice did not negate the earlier written admission. The rejection of the declaration for alleged non-quantification was therefore unsustainable, and the assessee was entitled to the Scheme benefit and discharge certificate.

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Issues: Whether, for the purposes of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, the assessee's tax dues were quantified on or before 30.06.2019 when the assessee had itself furnished written statements and calculation sheets admitting the duty liability, notwithstanding that the department issued the show cause notice later.

Analysis: Section 123(c) of the Finance Act No. 2 of 2019 applies where enquiry, investigation, or audit is pending and requires that the duty payable be quantified on or before 30.06.2019. Section 121(r) defines quantified as a written communication of the amount of duty payable under the indirect tax enactment. The Scheme is intended both to resolve disputes and to provide amnesty, and its coverage is not confined to cases where the department itself has issued the written quantification. A written communication emanating from the assessee can satisfy the definition if the amount is on record, is not disputed by the department, and reflects a credible admission of liability. The departmental circular also clarifies that a duty liability admitted during enquiry or investigation constitutes quantification. On the facts, the assessee had furnished the duty computation, the department proceeded on that basis, and the later show cause notice did not alter the fact that the liability had already been quantified in writing before the cut-off date.

Conclusion: The tax dues were quantified on or before 30.06.2019 and the rejection of the declaration on the ground of non-quantification was unsustainable. The issue is decided in favour of the assessee.

Final Conclusion: The declaration under the Scheme could not be rejected for want of quantification, and the assessee was entitled to the benefit of the Scheme and the discharge certificate.

Ratio Decidendi: For pending enquiry or investigation cases under the Scheme, "quantified" means a written communication of duty payable on record, and such quantification may validly arise from the assessee's own undisputed admission of liability before the statutory cut-off date.

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