Quantification of tax liability for Sabka Vishwas Scheme eligibility includes written admission before the cut-off date.

Eligibility under the Sabka Vishwas (Legacy Dispute Resolution) Scheme turned on whether duty liability had been quantified before 30 June 2019. The Court treated "quantified" as a written communication of the amount payable and held that an admitted, written disclosure of tax liability before the cut-off date satisfied that requirement. It further noted that the exclusion applies only where the amount had not been so quantified during enquiry, investigation, or audit. The petitioner was therefore eligible for the Scheme, and rejection of the declaration for want of prior quantification was invalid.

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Issues: Whether the petitioner was eligible for relief under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 when the tax liability had been admitted and quantified before 30 June 2019, and whether the rejection of the declaration on the premise that quantification was not completed before the cut-off date was valid.

Analysis: The Scheme treats "quantified" as a written communication of the amount of duty payable under the indirect tax enactment. The disqualifying clause applies only where, in an enquiry, investigation, or audit, the amount of duty involved has not been quantified on or before 30 June 2019. The material placed before the Court showed written declarations by the petitioner admitting the tax liability and setting out the quantified amount well before the cut-off date. The departmental circular also clarified that duty liability admitted during enquiry, investigation, or audit constitutes quantification for the Scheme.

Conclusion: The petitioner was eligible for the benefit of the Scheme, and the rejection of the declaration on the ground of absence of prior quantification was invalid.

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