Discharge certificate under Sabka Vishwas Scheme gives finality, barring further proceedings and Revenue challenge on the same dispute.

Issuance of a discharge certificate under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 gives conclusive finality to the dispute and period covered by the declaration. Once the designated committee accepts the declaration, determines the payable amount, receives payment, and issues Form SVLDRS-4, the matter cannot be reopened in later indirect tax proceedings. Where no corrective notice is issued by the committee to revise the declaration or determine a different amount, a parallel Revenue appeal on the same tax dispute is not maintainable and no further demand survives.

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Issues: (i) Whether, after issuance of a discharge certificate under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, the Revenue could sustain an appeal against the same tax dispute.

Analysis: The Scheme makes the declaration, verification, determination of amount payable, payment, and issuance of a discharge certificate part of a complete settlement mechanism. Once the designated committee accepts the declaration, determines the payable amount, receives payment, and issues Form SVLDRS-4, the certificate is conclusive as to the matter and period covered. The Scheme also provides that, on issuance of the discharge certificate, the matter covered cannot be reopened in any other proceeding under the indirect tax enactment. In the present case, the discharge certificate had already been issued, and no corrective notice was issued by the designated committee to dispute the declaration or determine a different amount.

Conclusion: The Revenue's appeal was not maintainable and no demand survived against the assessee after issuance of the discharge certificate.

Final Conclusion: A valid discharge certificate under the Scheme brings finality to the covered dispute and bars further proceedings on the same matter.

Ratio Decidendi: Issuance of a discharge certificate under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 conclusively settles the covered dispute and precludes reopening or continuation of proceedings on the same matter and period.

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