Prior quantification under Sabka Vishwas can be satisfied by a written admission of duty liability made before the cut-off date.

For the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, prior quantification is satisfied where the duty amount is recorded in a written communication on or before the statutory cut-off date, including an admission made during enquiry, investigation or audit. The Scheme and its clarificatory circular recognise written admissions, letters, and audit reports as sufficient quantification. On the stated facts, the recorded admission accepted the working-sheet calculation as correct before the cut-off date, and the denial of Scheme benefit on the basis that quantification occurred later was unsustainable.

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Issues: Whether the appellants' case satisfied the requirement of prior quantification so as to qualify for benefit under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019.

Analysis: The Scheme treats as tax dues, in cases of pending enquiry, investigation or audit, only the duty amount quantified on or before 30 June 2019, and defines quantified as a written communication of the amount of duty payable under the indirect tax enactment. The clarificatory circular also recognises written communications, including letters, admitted liability during enquiry, investigation or audit, and audit reports, as sufficient quantification. The statement recorded on 07.05.2019 contained an admission accepting the working-sheet calculation as correct, and the factual position that the main company had been extended the Scheme benefit on that basis was not disputed.

Conclusion: The appellants' claim fell within the Scheme and denial of benefit on the ground that quantification occurred only on 07.09.2019 was unsustainable.

Ratio Decidendi: For purposes of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, a written admission of duty liability recorded during enquiry, investigation or audit constitutes quantification if it is made on or before the statutory cut-off date.

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