Discharge certificate under Sabka Vishwas bars further adjudication on the settled tax demand unless revoked or cancelled first.

A discharge certificate issued under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 brings the covered service tax dispute to full and final settlement, so adjudication on the same demand cannot continue unless the certificate is first revoked or cancelled under the scheme. Continuing proceedings after issuance of the certificate would create parallel and conflicting orders over the same subject matter and disrupt the scheme's finality. The continuation of adjudication was therefore held impermissible, and the impugned order was set aside in favour of the assessee.

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Issues: Whether adjudication could continue in respect of the disputed service tax demand after issuance of the discharge certificate under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019.

Analysis: The discharge certificate issued under the scheme was treated as bringing the tax dispute to a full and final settlement for the covered period. The challenge to continued adjudication was examined in the light of the scheme provisions and the earlier High Court ruling relied upon by the Court. The reasoning adopted was that, once the Designated Committee has issued the discharge certificate, the adjudicating authority cannot proceed further unless that certificate is first revoked or cancelled in the manner contemplated by the scheme. Allowing adjudication to continue would also create conflicting and parallel orders over the same subject matter and disturb the administrative hierarchy.

Conclusion: The continuation of adjudication after issuance of the discharge certificate was held impermissible, and the impugned order was set aside in favour of the assessee.

Ratio Decidendi: Once a discharge certificate is issued under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, adjudication on the same settled tax demand cannot continue unless the certificate is first revoked or cancelled by the competent authority under the scheme.

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