SVLDRS eligibility turns on pre cut-off quantification through admitted liability, while delay and laches may not defeat relief.

Delay and laches were not treated as fatal where the writ challenge was filed after the rejection was communicated but the interval was not found unreasonable, especially in the context of COVID-19 disruption. Under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, quantification of tax dues by the cut-off date was satisfied by written communication and by the director's admission of short-paid liability before that date. The petitioner was not to be denied scheme eligibility merely because the investigation was concluded later or the departmental figure differed, and the rejection of the application was set aside with remand for fresh computation and consequential relief on payment with interest within time.

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Issues: (i) Whether the writ petition was liable to be rejected on the ground of delay and laches; (ii) whether the petitioner's application under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 was wrongly rejected for want of quantification of tax dues by the cut-off date.

Issue (i): Whether the writ petition was liable to be rejected on the ground of delay and laches

Analysis: The challenge was instituted after the impugned rejection had been communicated, but the interval was not treated as so unreasonable as to create any vested or parallel rights in favour of the respondents. The period also overlapped with the COVID-19 disruption. The cited comparison did not assist the respondents on the facts presented.

Conclusion: The objection based on delay and laches was rejected and is against the respondents.

Issue (ii): Whether the petitioner's application under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 was wrongly rejected for want of quantification of tax dues by the cut-off date

Analysis: The scheme requires quantification of tax dues as on the specified cut-off date, but the relevant clarification treated a written communication of duty demand as sufficient quantification, including statements recorded during enquiry or investigation. The petitioner's director had admitted the short-paid liability before the cut-off date, and the departmental material did not show a higher final liability than the amount already quantified by the petitioner. On that basis, the petitioner could not be treated as ineligible merely because the investigation was later finalised or adjustments were made. The equitable nature of the relief also justified a direction for interest on the amount ultimately payable.

Conclusion: The rejection of the petitioner's application was unsustainable, and the petitioner was eligible for the scheme benefits.

Final Conclusion: The rejection of the SVLDRS application was set aside, the matter was remanded for fresh computation, and consequential relief was made conditional upon payment of the amount determined along with interest within the stipulated period.

Ratio Decidendi: For purposes of SVLDRS eligibility, a written communication or statement evidencing admitted duty liability before the cut-off date constitutes quantification, and the scheme is not to be denied where the department's later assessment does not exceed the liability already quantified by the assessee.

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