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    <description>Eligibility under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 turns on whether an appeal was pending on the cut-off date, not on whether it had been numbered. Section 124(1)(a) links relief to tax dues arising from a show cause notice or pending appeal as on 30 June 2019, while Section 125(1)(a) excludes only appeals that had been finally heard on or before that date. On that basis, an appeal filed before the cut-off date remained within the litigation category, and its later reclassification as an arrears case was inconsistent with the statutory scheme.</description>
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