Final judicial interest liability falls outside a tax settlement scheme, barring reduction or liquidation of the concluded amount.

Interest imposed by a High Court as a condition of interim protection, and concluded by a final order, could not be treated as arrears eligible for liquidation under the Madhya Pradesh Bakaya Rashi Saral Samadhan Yojna, 2002. The scheme was confined to statutory tax, penalty and interest dues within its prescribed scope, and Clause 5(2) excluded matters requiring fresh assessment after remand. As the liability arose from a final judicial direction rather than from the entry tax enactment or the settlement scheme, it could not be reduced or settled under the scheme. The challenge to cancellation of the settlement certificate also failed, and no interference was called for.

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Issues: Whether the interest levied at 18% per annum pursuant to the High Court's earlier interim order could be brought within the settlement under the Madhya Pradesh Bakaya Rashi Saral Samadhan Yojna, 2002, and whether the cancellation of the settlement certificate issued under the scheme called for interference.

Analysis: The amount in question was not interest levied under the entry tax enactment or under the settlement scheme, but was interest directed by the High Court while granting interim protection, subject to payment if the petition failed. That order had attained finality. The scheme was confined to arrears of tax, penalty and interest falling within its prescribed ambit, and Clause 5(2) excluded cases requiring fresh assessment after remand. Since the liability under the High Court's order stood concluded, the amount could not be reduced or liquidated under the scheme. The Court also declined to reopen objections regarding cancellation of the certificate in view of the finality of the earlier decision.

Conclusion: The interest amount directed by the High Court was outside the scope of the Samadhan Scheme and could not be settled or reduced under it; the challenge to the cancellation order failed.

Final Conclusion: No interference was called for, and the writ petitions were dismissed as the settlement benefit was unavailable for the concluded interest liability.

Ratio Decidendi: A liability arising from a final judicial order imposing interest as a condition of interim protection cannot be treated as arrears eligible for liquidation under a settlement scheme confined to statutory tax-related dues.

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