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SVLDRS - The High Court acknowledged that the petitioner's duty liability was admitted and quantified before the cutoff date of 30.06.2019, as evidenced by records from the audit proceedings. The Court interpreted Section 125(1)(e) and Section 121(r) in conjunction with the CBIC Circular, emphasizing that admissions recorded during the audit process constituted a written communication of the duty payable. - It held that the rejection of the petitioner's declaration solely based on the date of issuance of the final audit report was not tenable, considering the clarification provided by the CBIC.
SVLDRS - The High Court acknowledged that the petitioner's duty liability was admitted and quantified before the cutoff date of 30.06.2019, as evidenced by records from the audit proceedings. The Court interpreted Section 125(1)(e) and Section 121(r) in conjunction with the CBIC Circular, emphasizing that admissions recorded during the audit process constituted a written communication of the duty payable. - It held that the rejection of the petitioner's declaration solely based on the date of issuance of the final audit report was not tenable, considering the clarification provided by the CBIC.
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