Sabka Vishwas Scheme eligibility depends on valid pre-cut-off quantification; disputed or unauthorised notices cannot establish entitlement.

Eligibility under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 depended on a valid pre-cut-off show-cause notice or other reliable quantification of tax dues. A notice dated 30.05.2016 did not quantify any amount and could not establish entitlement. Although a notice dated 28.05.2019 quantified dues, its genuineness and competence were disputed as it was said to have been issued by an incompetent authority and to be not genuine. On the material placed, there was no reliable basis to hold that the claimant had established a valid right to scheme relief, and the rejection of the application was upheld.

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Issues: Whether the petitioner was entitled to the benefit of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 on the basis of the notices relied upon, and whether the rejection of the application was liable to be interfered with.

Analysis: The scheme applied to tax dues where a qualifying show-cause notice or equivalent quantification existed on or before the cut-off date. The notice dated 30.05.2016 did not quantify any amount and therefore did not establish eligibility. The notice dated 28.05.2019 quantified tax dues, but its genuineness and competence were specifically disputed by the respondents on the basis that it was issued by an incompetent authority and appeared to be not genuine. On the material placed before it, the Court found no reliable basis to hold that the petitioner had established a valid entitlement under the scheme.

Conclusion: The petitioner was not entitled to the scheme benefit and the rejection of the application was upheld.

Ratio Decidendi: To claim relief under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, the claimant must establish a valid pre-cut-off quantification or qualifying notice, and the Designated Committee may reject a claim founded on documents found to be unauthorised or not genuine.

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