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    <title>2000 (11) TMI 19 - GUJARAT High Court</title>
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    <description>Paragraph 2 of the Kar Vivad Samadhan Scheme (Removal of Difficulties) Order, 1998 was interpreted as limited to co-noticees whose proceedings were still at the demand notice or show-cause notice stage, and it did not extend settlement benefits to co-noticees whose penalty had already been adjudicated and was in appeal. The court also held that this distinction was not discriminatory under Article 14 because co-noticees at the notice stage and those in appellate proceedings constituted different classes with a rational nexus to the Scheme&#039;s object of speedy revenue recovery and reduced litigation. The challenge to the scope and validity of paragraph 2 therefore failed.</description>
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      <title>2000 (11) TMI 19 - GUJARAT High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=12918</link>
      <description>Paragraph 2 of the Kar Vivad Samadhan Scheme (Removal of Difficulties) Order, 1998 was interpreted as limited to co-noticees whose proceedings were still at the demand notice or show-cause notice stage, and it did not extend settlement benefits to co-noticees whose penalty had already been adjudicated and was in appeal. The court also held that this distinction was not discriminatory under Article 14 because co-noticees at the notice stage and those in appellate proceedings constituted different classes with a rational nexus to the Scheme&#039;s object of speedy revenue recovery and reduced litigation. The challenge to the scope and validity of paragraph 2 therefore failed.</description>
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