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Issues: Whether the petitioner's service tax dues were quantified on or before 30 June 2019 so as to make the declaration under the Sabka Vishwas Legacy Dispute Resolution Scheme, 2019 maintainable, and whether rejection of the declaration on the ground of ineligibility was justified.
Analysis: The petitioner had addressed a letter dated 6 May 2019 admitting a quantified service tax liability of Rs. 22,00,414/-, and the department subsequently called upon the petitioner to pay that amount. On the facts, the written communication constituted quantification before the cut-off date. The scheme treats quantified dues as written communication of the amount payable, including a duty demand or liability admitted during enquiry, investigation, or audit. The rejection based on the absence of pre-cut-off quantification was therefore contrary to the record and to the scheme's object of settling legacy service tax disputes through a liberal approach.
Conclusion: The petitioner's dues were quantified before 30 June 2019, and the rejection of the declaration was unjustified. The declaration was required to be reconsidered in accordance with law, and the consequential adverse orders were liable to be set aside.
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