Written communication of duty liability before the cut-off date can satisfy quantification under the legacy dispute resolution scheme.

A duty demand is treated as quantified under the Sabka Vishvas (Legacy Dispute Resolution) Scheme, 2019 when the payable amount is communicated in writing before the cut-off date, including through departmental correspondence or admitted liability during enquiry. Later scrutiny does not undo that quantification if the written record already reflected the liability. On that basis, a declarant is eligible to file under the scheme where the demand stood so communicated before 30.06.2019, and a rejection based solely on non-quantification is unsustainable.

---

---

Issues: Whether the petitioner was ineligible under Section 125(1)(e) of the Finance (No. 2) Act, 2019 to file a declaration under the Sabka Vishvas (Legacy Dispute Resolution) Scheme, 2019 on the ground that the duty demand had not been quantified by the cut-off date.

Analysis: The petitioner's liability was communicated in writing before 30.06.2019 through departmental letters acknowledging the tax demand and the amounts deposited. The written communication reflected the duty liability during the enquiry, and the later scrutiny did not detract from the fact that the demand had already been quantified within the meaning of the scheme and the governing clarification. On that basis, the petitioner fell within the class of eligible declarants under the scheme.

Conclusion: The ineligibility order was unsustainable and the petitioner was entitled to be treated as eligible to make a declaration under the scheme.

Final Conclusion: The impugned rejection was set aside and the matter was sent back for a fresh decision under the scheme after treating the petitioner as eligible.

Ratio Decidendi: A duty demand is quantified for the purposes of the Sabka Vishvas (Legacy Dispute Resolution) Scheme, 2019 when there is a written communication of the payable amount before the cut-off date, including departmental correspondence or admitted liability during enquiry or investigation.

---