Pre-deposit adjustment under Sabka Vishwas Scheme must be deducted when computing final payable tax dues.

Under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, pre-deposits made during appellate proceedings or investigation had to be deducted while computing the amount payable, because relief under Section 124(1)(c) was to be applied to the tax dues finally determined and Section 124(2) required adjustment of amounts already paid. The Madras HC held that once the declarant's liability reached the stage of "amount in arrears" after the appellate order became final, the impugned statement had incorrectly quantified the dues by omitting that statutory deduction. It also corrected the petitioner's own calculation and fixed the revised payable amount for settlement under the scheme.

---

---

Issues: Whether the amount pre-deposited by the declarant was required to be deducted while computing the amount payable under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, and whether the statement issued under the scheme had correctly quantified the tax dues.

Analysis: The declarant's tax liability had attained the stage of "amount in arrears" after the appellate order became final. Under the scheme, relief under Section 124(1)(c) had to be computed on the tax dues determined in the order-in-original as affirmed in appeal, and Section 124(2) mandated deduction of any pre-deposit or deposit already made during appellate proceedings or investigation. On that basis, the pre-deposited amount had to be set off against the payable amount, and the computation made in the impugned statement was found to be incorrect. The Court also corrected the petitioner's own computation and determined the revised amount payable after applying the statutory relief and deduction of pre-deposit.

Conclusion: The pre-deposit was required to be adjusted under the scheme, and the amount payable had to be recomputed. The petitioner was granted partial relief, with direction to pay the revised quantified amount for settlement under the scheme.

---