Sabka Vishwas eligibility turns on pre-30.06.2019 enquiry, investigation, or audit for ineligibility under Section 125(f).

Section 125(f) of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 was read to require that any enquiry, investigation, or audit must have been initiated before 30.06.2019. The Scheme treats that date as the operative cut-off across its eligibility and relief provisions, and consistency with the Department's own interpretation in comparable matters supported the same reading here. Because the petitioner received the enquiry letter only on 10.10.2019, the ineligibility under Section 125(f) did not apply, and the petitioner was entitled to the Scheme's benefit.

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Issues: Whether a person subjected to enquiry, investigation, or audit after 30.06.2019 was ineligible under Section 125(f) of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, and whether the petitioner was entitled to relief under the Scheme.

Analysis: The Scheme repeatedly uses 30.06.2019 as the relevant watershed date in several provisions dealing with tax dues, relief, and eligibility. Though Section 125(f) does not expressly repeat that date, the Department had itself accepted in other matters that the enquiry, investigation, or audit contemplated by that clause must have occurred prior to 30.06.2019. Once the revenue adopted that interpretation in comparable cases, consistency required the same view to be applied in identical matters. The petitioner had received the enquiry letter only on 10.10.2019, which was after the cut-off date.

Conclusion: Section 125(f) was held to require that the enquiry, investigation, or audit must have been initiated before 30.06.2019. The petitioner was not hit by that ineligibility and was entitled to the benefit of the Scheme.

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