Redemption fine falls within Sabka Vishwas relief, supporting discharge certificate and refund after scheme compliance.

Redemption fine imposed in confiscation proceedings arising from excise duty default was treated as covered by the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019. The Scheme was read to extend to the waiver and settlement framework for duty, interest, penalty and fine, and its object of finality supported inclusion of redemption fine. Once the declarant satisfied the Scheme requirements by paying the determined amount and withdrawing the appeal, separate insistence on redemption fine was unsustainable. The petitioner was entitled to a discharge certificate and refund of the amount recovered towards redemption fine with statutory interest.

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Issues: Whether redemption fine imposed in confiscation proceedings is covered by the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, and whether the declarant is entitled to a discharge certificate and refund of the amount recovered towards redemption fine.

Analysis: The Scheme was construed in the context of its defined expressions, particularly the provisions dealing with tax dues, amount payable, relief, and discharge certificate. The Court held that confiscation and redemption fine arise as consequences of non-payment of excise duty, and that redemption fine is not a separate category outside the Scheme's waiver of duty, interest, and penalty. It relied on the Scheme's object of bringing finality to legacy disputes, the CBIC's FAQs and flyer referring to total waiver of interest, penalty and fine, and the consistent view taken by other High Courts that redemption fine is included within the Scheme's coverage. The Court further held that once the petitioner had complied with the Scheme by paying the amount determined under it and withdrawing the appeal, the insistence on separate payment of redemption fine was unsustainable.

Conclusion: Redemption fine was held to be covered by the Scheme, and the petitioner was entitled to a discharge certificate as well as refund of the amount recovered towards redemption fine with statutory interest.

Final Conclusion: The petition succeeded, the petitioner's liability under the Scheme was treated as settled, and the Department was directed to complete the consequential reliefs.

Ratio Decidendi: Where redemption fine is imposed as a consequence of confiscation arising from excise duty default, and the declarant otherwise satisfies the Sabka Vishwas Scheme requirements, redemption fine is treated as part of the Scheme's relief from duty, interest, penalty, and fine, and cannot be insisted upon as a separate prerequisite for discharge.

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