TaxTMI Login
AI Drafter - (New and Powerful) ✕
Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
Just a moment...
AI Drafter - (New and Powerful) ✕ Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
Press 'Enter' to add multiple search terms. Rules for Better Search
Use comma for multiple locations.
---------------- For section wise search only -----------------
Accuracy Level ~ 90%
of 
Press 'Enter' after typing page number.
of Press 'Enter' after typing page number.
No Folders have been created
Are you sure you want to delete "My most important" ?
NOTE:
of Press 'Enter' after typing page number.
of Press 'Enter' after typing page number.
All Case Laws
of Press 'Enter' after typing page number.
of Press 'Enter' after typing page number.
All Case Laws
Note
Bookmark
Share
Don't have an account? Register Here
of Press 'Enter' after typing page number.
Issues: Whether the impugned SVLDRS-3, which rejected the objections raised in SVLDRS-2A without assigning reasons, required interference and reconsideration under Section 126 of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 read with Rule 6 of the Sabka Vishwas (Legacy Dispute Resolution) Scheme Rules, 2019.
Analysis: The impugned form did not disclose any reason for rejecting the declarant's detailed explanation that the turnover had been reported twice in the ST-3 return. The Scheme contemplates verification of the correctness of the declaration, and the Designated Committee is required to examine the particulars furnished by the declarant along with the departmental records. Where the declarant sets out specific reasons for disagreement, at least brief reasons are expected in the disposal of those objections. The absence of such reasons showed that the matter had not been considered with the requisite application of mind.
Conclusion: The SVLDRS-3 was liable to be set aside and the matter had to be reconsidered by the Authority.
Final Conclusion: The matter was remitted to the Designated Committee for fresh consideration, with all contentions kept open and no opinion expressed on the merits.
Ratio Decidendi: A Designated Committee acting under the SVLDRS framework must give at least brief reasons while rejecting specific objections to a declaration, and a non-speaking rejection is liable to be set aside for reconsideration.
TaxTMI 
