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    <title>2023 (2) TMI 611 - PUNJAB AND HARYANA HIGH COURT</title>
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    <description>Sections 124(2) and 130(2) of the Finance Act, 2019, in the Vivad se Vishwas Scheme, were upheld against an Article 14 challenge because the denial of refund for excess amounts already paid formed part of the scheme&#039;s legislative design for settling legacy indirect tax disputes. The Court treated the scheme as a one-time dispute resolution mechanism, not an amnesty or fresh levy, and held that taxation classifications are tested with greater latitude. The distinction between declarants who paid only the required pre-deposit and those who paid more was found to have a rational nexus with the object of resolving pending disputes, so the hostile discrimination challenge failed.</description>
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      <description>Sections 124(2) and 130(2) of the Finance Act, 2019, in the Vivad se Vishwas Scheme, were upheld against an Article 14 challenge because the denial of refund for excess amounts already paid formed part of the scheme&#039;s legislative design for settling legacy indirect tax disputes. The Court treated the scheme as a one-time dispute resolution mechanism, not an amnesty or fresh levy, and held that taxation classifications are tested with greater latitude. The distinction between declarants who paid only the required pre-deposit and those who paid more was found to have a rational nexus with the object of resolving pending disputes, so the hostile discrimination challenge failed.</description>
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