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    <title>2021 (11) TMI 463 - KARNATAKA HIGH COURT</title>
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    <description>The Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 was construed as a beneficial amnesty and dispute-resolution measure requiring liberal interpretation. Section 124 was read as allowing deduction of amounts already paid as pre-deposit while determining the amount payable, and its reference to a show-cause notice and related appeals was treated as broad enough to cover multiple proceedings involving the same assessee and subject matter. On that basis, excess pre-deposit paid in relation to the first notice could be adjusted against liability under the second notice, especially where both disputes involved the same petitioner and commodity but different periods. The requirement of a separate declaration under Rule 3(2) was treated as procedural, not a bar to adjustment.</description>
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      <link>https://www.taxtmi.com/caselaws?id=414682</link>
      <description>The Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 was construed as a beneficial amnesty and dispute-resolution measure requiring liberal interpretation. Section 124 was read as allowing deduction of amounts already paid as pre-deposit while determining the amount payable, and its reference to a show-cause notice and related appeals was treated as broad enough to cover multiple proceedings involving the same assessee and subject matter. On that basis, excess pre-deposit paid in relation to the first notice could be adjusted against liability under the second notice, especially where both disputes involved the same petitioner and commodity but different periods. The requirement of a separate declaration under Rule 3(2) was treated as procedural, not a bar to adjustment.</description>
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