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CESTAT allowed the appeal, holding the appellant eligible for benefit under the VCES. It held that service tax deposited prior to the formal enactment and prior to acknowledgment of the declaration could be treated as payment towards "tax dues" under the scheme, given its beneficial and voluntary-compliance objective. The Tribunal applied purposive interpretation, preferring substantive rights over procedural technicalities, and concluded that the appellant had duly complied with statutory requirements. Consequently, rejection of the VCES-I declaration by the Designated Authority was found unsustainable, the impugned order was set aside, and the declaration was held valid with consequential reliefs.
CESTAT allowed the appeal, holding the appellant eligible for benefit under the VCES. It held that service tax deposited prior to the formal enactment and prior to acknowledgment of the declaration could be treated as payment towards "tax dues" under the scheme, given its beneficial and voluntary-compliance objective. The Tribunal applied purposive interpretation, preferring substantive rights over procedural technicalities, and concluded that the appellant had duly complied with statutory requirements. Consequently, rejection of the VCES-I declaration by the Designated Authority was found unsustainable, the impugned order was set aside, and the declaration was held valid with consequential reliefs.
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