Sabka Vishwas Scheme relief is limited to statutory deposits, and eligibility depends on quantification by the cutoff date.

Under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, amounts paid during investigation are deductible only if they qualify as pre-deposit in appellate proceedings or as a deposit during enquiry, investigation, or audit. Voluntary tax payments made without being shown as deposits under protest do not fall within Section 124(2) and are not available for relief computation. The Scheme also requires that investigation-based dues be quantified by 30 June 2019 for eligibility under Section 125. Where quantification occurred only later, the declarant does not satisfy the statutory conditions for the Scheme benefit.

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Issues: (i) Whether amounts paid by the declarant during the course of investigation could be deducted while computing relief under Section 124(2) of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019. (ii) Whether a declarant whose dues were not quantified on or before 30 June 2019 could validly avail the Scheme under Section 125.

Issue (i): Whether amounts paid by the declarant during the course of investigation could be deducted while computing relief under Section 124(2) of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019.

Analysis: Section 124(2) permits deduction only of amounts paid as pre-deposit in appellate proceedings or as deposit during enquiry, investigation or audit. Amounts remitted voluntarily as tax dues, without being shown to be pre-deposit or deposit under protest, do not fall within that language. Where the payments were made as voluntary discharge of tax liability, the Scheme does not treat them as deductible amounts for calculating the payable sum.

Conclusion: The claim for deduction of the amounts voluntarily paid during investigation was rejected and the deduction was held to be unavailable.

Issue (ii): Whether a declarant whose dues were not quantified on or before 30 June 2019 could validly avail the Scheme under Section 125.

Analysis: Section 125 excludes persons subjected to enquiry, investigation or audit where the duty involved had not been quantified by the stipulated date. The material showed that quantification took place only after the investigation culminated in the later show cause notice, and the declarant's payments were treated as voluntary disclosures rather than disputed dues. On that basis, the declarant did not satisfy the statutory eligibility conditions for the Scheme.

Conclusion: The declarant was held not eligible to claim the Scheme benefit on the facts of the case.

Final Conclusion: The impugned demand under the Scheme was sustained, and no interference was warranted with the view taken by the learned Single Judge.

Ratio Decidendi: Relief under the Scheme is confined to statutorily specified deductions, and voluntary tax payments made during investigation are not deductible unless they qualify as pre-deposit or as a protected deposit within the scheme language; further, quantification by the cutoff date is a condition of eligibility where investigation-based dues are concerned.

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