Written quantification under legacy dispute scheme includes audit communication, making the declaration eligible despite later figure adjustments.

Under the Sabka Visvas (Legacy Dispute Resolution) Scheme, 2019, a declaration in the investigation, enquiry or audit category is maintainable only if the duty liability was quantified on or before 30.06.2019. The Madras HC treated the audit communication dated 31.05.2019 as sufficient written quantification because it identified the liability, and later correspondence merely reiterated or adjusted the figures. On that basis, the court held that a written communication of the amount payable, including an audit report or similar communication, satisfies the scheme requirement. The petitioner's declaration was therefore eligible, and the rejection was unsustainable.

---

---

Issues: Whether the petitioner's declaration under the Sabka Visvas (Legacy Dispute Resolution) Scheme, 2019, filed under the category of investigation, enquiry or audit, was maintainable and eligible when the tax liability had been quantified by the audit department on or before 30.06.2019.

Analysis: The scheme required, for cases falling under investigation, enquiry or audit, that the duty liability be quantified on or before 30.06.2019. The audit communication dated 31.05.2019 showed that the department had identified and quantified the liability, and the subsequent correspondence only reiterated or adjusted the figures. The Court treated such written communication as sufficient quantification within the meaning of the scheme, relying on the statutory scheme and the clarification that a written communication of the amount payable, including an audit report or similar communication, satisfies the requirement of quantification.

Conclusion: The petitioner's declaration was eligible under the scheme and the rejection was unsustainable.

---