Scheme computation must credit investigation deposits toward tax dues, and correcting an calculation does not extend time limits.

Amounts deposited during investigation toward the disputed tax liability had to be credited while computing the amount payable under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, because the deposit was later appropriated against the liability in the order-in-original. The Designated Committee erred by treating only the appeal pre-deposit as relevant and by issuing Form SVLDRS-3 on an incorrect computation. Correcting that mistake did not amount to extending the Scheme time limit, as the issue was recalculation of dues rather than a belated payment. The tax dues were therefore required to be recomputed after giving credit for the earlier deposit, and discharge followed on payment of the corrected amount.

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Issues: Whether the amount deposited during investigation had to be treated as payment towards the outstanding tax liability for computing the amount payable under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, and whether directing reconsideration of the computation would amount to impermissibly extending the time under the Scheme.

Analysis: The amount of Rs. 30,36,101/- had been deposited by the petitioner during investigation and was later appropriated against the tax liability in the order-in-original. That amount ought to have been taken into account as payment towards the outstanding dues while computing the amount payable under the Scheme, rather than treating only the appeal pre-deposit as relevant. The Designated Committee therefore committed a computation error in arriving at the figure in Form SVLDRS-3. Granting relief on that basis did not amount to extending the time limit under the Scheme, because the issue was not a late deposit but correction of an incorrect calculation made by the authority.

Conclusion: The computation under the Scheme was required to be corrected by giving credit for the amount deposited during investigation, and the petitioner was entitled to settle the matter on that basis.

Final Conclusion: The petition was allowed to the extent that the tax dues under the Scheme had to be recomputed after accounting for the earlier deposit, and the discharge certificate was to follow upon payment of the corrected amount.

Ratio Decidendi: Amounts actually deposited towards the disputed liability during investigation must be given credit in computing settlement dues under a beneficial settlement scheme, and correction of an erroneous computation does not amount to impermissible extension of the scheme period.

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