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Issues: Whether the penalties imposed on the individual appellants could survive after the principal noticee obtained relief under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 and the related proceedings stood concluded.
Analysis: The scheme under Chapter V of the Finance Act, 2019 was directed to settlement of legacy disputes on the basis of tax dues, with relief extending to interest, penalty and other consequences. The eligibility and quantum of relief were tied to the existence of pending duty demand and the amount of tax dues. Once the principal noticee was granted the prescribed relief and the duty-linked proceedings were resolved, continuation of penalties against the individual appellants was found inconsistent with the object and operation of the scheme. The Tribunal held that the appellants were entitled to erasure of the penalties imposed on them.
Conclusion: The penalties against the individual appellants did not survive and were liable to be set aside.
Final Conclusion: The appeals were allowed and the impugned order was set aside, resulting in deletion of the penalties imposed on the individual appellants.
Ratio Decidendi: Where a legacy dispute resolution scheme grants relief to the principal noticee on the duty demand, consequential penalties imposed on connected individuals cannot be sustained if the scheme's relief and structure no longer support their continuation.