Quantification of duty before the cut-off date was essential for scheme eligibility; later demand could not cure ineligibility.

Eligibility under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 depended on duty being quantified by a written communication on or before 30 June 2019. In an audit context, a mere letter supplying information for verification did not amount to quantification of duty payable, and the first actual demand issued later could not satisfy the cut-off. Because the declarant failed the threshold requirement under Section 125(1), the hearing provisions under Section 127(3) and (4) were not attracted. The rejection of the declaration was therefore valid, and the absence of a pre-decisional hearing did not vitiate the decision.

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Issues: Whether the petitioner was eligible to avail the benefit of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 on the basis that the duty had been quantified on or before 30 June 2019, and whether rejection of the declaration without hearing vitiated the decision.

Analysis: The scheme treated "quantified" as a written communication of the amount of duty payable. For cases under audit, the relevant precondition was that the duty involved had been quantified on or before the cut-off date. The petitioner's letter of 27 May 2019 merely furnished information for audit and did not communicate any duty liability payable. The first real communication of duty demand came later in the show cause notice dated 14 January 2020. Since the petitioner was ineligible at the threshold under Section 125(1), the hearing procedure under Section 127(3) and (4) was not attracted. The absence of a pre-decisional hearing therefore did not assist the petitioner.

Conclusion: The petitioner was not eligible under the scheme because no quantification of duty existed on or before 30 June 2019, and the rejection of the declaration was valid.

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