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HC ruled on tax settlement scheme interpretation regarding admitted versus disputed tax amounts. Settlement Officer erroneously deducted pre-deposit from disputed amount before applying 60% waiver under scheme. On Rs. 5,94,03,043 disputed amount (difference between determined tax Rs. 6,27,82,418 and admitted tax Rs. 33,79,374), petitioner was entitled to 60% waiver on full disputed sum without pre-deposit adjustment. Court set aside appellate authority's order, directed recalculation of settlement amount without deducting Rs. 49,00,000 pre-deposit from disputed amount before applying waiver. Ordered refund of excess amount with 6% interest per annum from deposit date until refund. Court emphasized liberal interpretation of beneficial tax legislation per precedent.
HC ruled on tax settlement scheme interpretation regarding admitted versus disputed tax amounts. Settlement Officer erroneously deducted pre-deposit from disputed amount before applying 60% waiver under scheme. On Rs. 5,94,03,043 disputed amount (difference between determined tax Rs. 6,27,82,418 and admitted tax Rs. 33,79,374), petitioner was entitled to 60% waiver on full disputed sum without pre-deposit adjustment. Court set aside appellate authority's order, directed recalculation of settlement amount without deducting Rs. 49,00,000 pre-deposit from disputed amount before applying waiver. Ordered refund of excess amount with 6% interest per annum from deposit date until refund. Court emphasized liberal interpretation of beneficial tax legislation per precedent.
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