Sabka Vishwas finality prevents further interest demands, and a mistaken scheme category cannot defeat eligible settlement benefit.

A discharge certificate issued under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 was conclusive for the covered matter and period, so later show cause notices demanding further interest were inconsistent with the scheme's finality and were set aside. The court also held that a declaration filed under the wrong scheme category did not defeat substantive eligibility where the taxpayer was otherwise entitled to relief and the mistake was merely clerical or classificatory. The declaration could be treated under the correct category, preserving the scheme benefit and preventing denial of settlement relief on a technical error.

---

---

Issues: (i) Whether a discharge certificate issued under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 barred the Revenue from issuing show cause notices demanding further interest for the same matter and period. (ii) Whether a declaration filed under the wrong category in the scheme could be corrected so that the declarant was not denied the scheme benefit.

Issue (i): Whether a discharge certificate issued under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 barred the Revenue from issuing show cause notices demanding further interest for the same matter and period.

Analysis: The amount of tax dues had been quantified before the cut-off date and the petitioner had thereafter paid the amount determined under the scheme. Once Form SVLDRS-4, the discharge certificate, was issued, the statutory scheme treated it as conclusive of the matter and the time period covered by the declaration. The scheme expressly provided that the declarant would not be liable to pay any further duty, interest or penalty in respect of the covered matter, and that the matter could not be reopened in other proceedings. The later notices demanding interest were therefore inconsistent with the finality attached to the discharge certificate and with the object of the scheme.

Conclusion: The subsequent show cause notices demanding interest for the covered period were unsustainable and were liable to be set aside.

Issue (ii): Whether a declaration filed under the wrong category in the scheme could be corrected so that the declarant was not denied the scheme benefit.

Analysis: The record showed that the petitioner had been eligible under the enquiry, investigation or audit category, and the quantification had already occurred before the statutory cut-off date. Filing the declaration under the arrears category was an inadvertent mistake and did not alter the underlying eligibility. The scheme and the relevant provision permitting rectification of clerical errors supported correction of such mistakes where the substantive entitlement was otherwise clear. Denial of relief merely because of the wrong category entry would defeat the beneficial object of the scheme.

Conclusion: The petitioner was entitled to have the declaration considered under the correct category, and the mistaken filing did not defeat the scheme benefit.

Final Conclusion: The petition succeeded, the scheme discharge was given full effect, and the Revenue was directed not to pursue further demand inconsistent with the settlement already concluded under the scheme.

Ratio Decidendi: A discharge certificate issued under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 is conclusive for the covered matter and period, and once issued it bars further duty, interest or penalty proceedings for that matter; an apparent clerical or categorisation error in the declaration cannot be used to defeat an otherwise vested statutory benefit under the scheme.

---