Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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The High Court held that the petitioner is eligible to avail the benefit of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, as the duty liability was admitted and quantified before June 30, 2019, during the course of investigation. The definition of "quantified" under the scheme does not specify who is required to quantify the amount. The ministry's clarification also stated that duty liability admitted and quantified before June 30, 2019, would be eligible under the scheme. Despite mentioning a higher figure in the application, the petitioner cannot be deprived of the scheme's benefit, especially when the scheme aims to reduce litigation. The High Court directed the respondents to accept the petitioner's application and inform any amount due and payable under the scheme within four weeks.
The High Court held that the petitioner is eligible to avail the benefit of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, as the duty liability was admitted and quantified before June 30, 2019, during the course of investigation. The definition of "quantified" under the scheme does not specify who is required to quantify the amount. The ministry's clarification also stated that duty liability admitted and quantified before June 30, 2019, would be eligible under the scheme. Despite mentioning a higher figure in the application, the petitioner cannot be deprived of the scheme's benefit, especially when the scheme aims to reduce litigation. The High Court directed the respondents to accept the petitioner's application and inform any amount due and payable under the scheme within four weeks.
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