Redemption fine linked to confiscated goods remains eligible for settlement under the legacy indirect-tax dispute resolution scheme.

Redemption fine imposed in lieu of confiscation is covered by the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 because the statutory exclusions do not include confiscation or liability to redemption fine. The notes state that redemption fine is inseparable from the recoverable duty demand and that excluding it would conflict with the Scheme's objective of resolving legacy indirect-tax disputes. A declaration cannot therefore be rejected solely because it includes redemption fine, and an assessee remains eligible to seek settlement under the Scheme.

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Issues: Whether redemption fine imposed in lieu of confiscation of goods is covered by the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, so that a declarant is eligible to seek settlement.

Analysis: Section 125 of the Finance (No. 2) Act, 2019 specifies the categories excluded from making a declaration under the Scheme. Confiscation of goods or liability to redemption fine is not among those exclusions. The Scheme's objective of resolving legacy indirect-tax disputes, together with the treatment of redemption fine as inseparable from the recoverable duty demand, does not permit rejection of a declaration solely because it includes redemption fine. The departmental interpretation excluding redemption fine from the Scheme was inconsistent with the statutory framework.

Conclusion: Redemption fine in lieu of confiscation is covered by the Scheme, and the assessee is eligible to file a declaration notwithstanding inclusion of redemption fine.

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