Sabka Vishwas relief covers redemption fine and related confiscation proceedings, ensuring full settlement of the legacy dispute.

Under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, redemption fine arising from confiscation proceedings linked to excise duty disputes is treated as part of the scheme-covered liability, so separate payment of redemption fine is not required for discharge. The text also states that two show cause notices concerning the same underlying dispute cannot be fragmented into separate liabilities once settlement is reached; discharge for the later notice extends to the earlier confiscation-related proceedings as well. The overall effect described is final settlement of the legacy dispute without preserving redemption-fine exposure separately.

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Issues: (i) Whether redemption fine is covered within the relief under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, so that discharge under the Scheme can be granted without insisting on separate payment of redemption fine. (ii) Whether the show cause notices dated 18 June 2013 and 16 June 2014 concern the same matter, such that the discharge certificate issued for the latter also concludes the proceedings arising from the former.

Issue (i): Whether redemption fine is covered within the relief under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, so that discharge under the Scheme can be granted without insisting on separate payment of redemption fine.

Analysis: The Scheme was construed as a settlement mechanism intended to bring finality to legacy indirect tax disputes. Its definitions and relief provisions were read together with the Central Excise framework governing seizure, confiscation, and fine in lieu of confiscation. Redemption fine was treated as a consequence of confiscation arising from non-payment of excise duty, and therefore as part of the composite liability addressed by the Scheme. The public-facing FAQs and flyer issued by the Board, which referred to waiver of interest, penalty and fine, were treated as supporting the same understanding. The Court also followed the consistent view taken by other High Courts that redemption fine is not to be excluded from the Scheme's relief.

Conclusion: Redemption fine is covered by the Scheme and separate payment of redemption fine cannot be insisted upon for issuance of discharge.

Issue (ii): Whether the show cause notices dated 18 June 2013 and 16 June 2014 concern the same matter, such that the discharge certificate issued for the latter also concludes the proceedings arising from the former.

Analysis: The Court found that the two show cause notices arose from the same underlying subject matter and the confiscation-related proceedings were part of the same dispute matrix. Once the duty liability was settled under the Scheme in relation to the later notice, the redemption fine and penalty linked to the earlier confiscation notices could not survive independently. The Scheme was applied to prevent fragmentation of one dispute into separate payable components after settlement.

Conclusion: The two show cause notices pertain to the same matter, and the discharge certificate issued for the later notice extends to the earlier confiscation proceedings as well.

Final Conclusion: The petitions succeed, and the petitioners are entitled to discharge certificates for the earlier show cause notices without separate insistence on redemption fine, thereby bringing the entire legacy dispute to an end.

Ratio Decidendi: Under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, redemption fine arising from confiscation proceedings consequent to excise duty disputes forms part of the scheme-covered liability and is waived on settlement of the tax dues; the scheme must be applied to secure finality of the whole dispute rather than to preserve redemption-fine liability separately.

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