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HC held that appellant was eligible for benefits under Karasamadhana Scheme, 2021, despite subsequent initiation of suo-motu revision proceedings under Section 64(1) of KVAT Act. Court ruled that Clause 5.7 of the scheme only disqualifies dealers against whom revision proceedings were already initiated before the scheme's notification date. Since no suo-motu revision was pending when the scheme was introduced, and appellant's application was accepted with order passed in their favor, subsequent initiation of revisional proceedings would defeat the scheme's purpose and object. Permitting post-acceptance revision would render the scheme arbitrary and unreasonable. Appeal allowed in favor of assessee-appellant.
HC held that appellant was eligible for benefits under Karasamadhana Scheme, 2021, despite subsequent initiation of suo-motu revision proceedings under Section 64(1) of KVAT Act. Court ruled that Clause 5.7 of the scheme only disqualifies dealers against whom revision proceedings were already initiated before the scheme's notification date. Since no suo-motu revision was pending when the scheme was introduced, and appellant's application was accepted with order passed in their favor, subsequent initiation of revisional proceedings would defeat the scheme's purpose and object. Permitting post-acceptance revision would render the scheme arbitrary and unreasonable. Appeal allowed in favor of assessee-appellant.
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