Natural justice under Sabka Vishwas requires Form SVLDRS-2 and personal hearing before finalising a disputed liability.

Where the amount payable under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 is disputed, the Designated Committee must first follow the statutory sequence under section 127 and Rule 6 by issuing Form SVLDRS-2 and granting a personal hearing before finalising the amount. Bypassing that procedure and issuing Form SVLDRS-3 straightaway deprives the declarant of the scheme's procedural safeguards and offends natural justice. The final form is therefore unsustainable if issued without the prescribed estimate and hearing, and the matter must be reconsidered after compliance with the statutory process.

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Issues: Whether the Designated Committee could issue Form SVLDRS-3 without first issuing Form SVLDRS-2 and granting the declarant an opportunity of personal hearing where the amount payable under the scheme was disputed.

Analysis: Section 127 of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 and Rule 6 of the Sabka Vishwas (Legacy Dispute Resolution Scheme) Rules, 2019 require the Designated Committee, where it estimates the amount payable to be higher than the amount declared, to issue an estimate in Form SVLDRS-2 and afford an opportunity of personal hearing. The declarant had disputed the amount payable in the declaration itself. Issuing Form SVLDRS-3 straightaway, without following the statutory sequence and without hearing the declarant, deprived the declarant of the procedural safeguards contemplated by the Scheme and offended principles of natural justice.

Conclusion: The issuance of Form SVLDRS-3 without first issuing Form SVLDRS-2 and granting a personal hearing was impermissible, and the challenge succeeded in favour of the assessee.

Final Conclusion: The impugned determination was set aside and the matter was sent back for fresh decision after compliance with the prescribed statutory procedure.

Ratio Decidendi: Where the amount payable under the Sabka Vishwas scheme is disputed, the Designated Committee must first issue the statutory estimate and provide a personal hearing before finalising the amount payable; bypassing that procedure renders the final form unsustainable.

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