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    <title>2023 (6) TMI 1002 - GUJARAT HIGH COURT</title>
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    <description>An amount deposited pursuant to appellate tribunal directions was held not to count as tax dues for computing relief under the Sabka Vishvas (Legacy Dispute Resolution) Scheme, 2019, because it had been paid towards penalty rather than tax. On that basis, the balance amount payable under Clause 124 was correctly determined by the respondents. However, where the petitioners made a bona fide attempt to remit the determined sum within the extended Scheme period and the payment failed for a technical reason beyond their control, the substantive benefit of the Scheme could not be denied on procedural grounds. The petitioners were therefore entitled to avail the Scheme on payment of the determined amount with interest.</description>
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      <description>An amount deposited pursuant to appellate tribunal directions was held not to count as tax dues for computing relief under the Sabka Vishvas (Legacy Dispute Resolution) Scheme, 2019, because it had been paid towards penalty rather than tax. On that basis, the balance amount payable under Clause 124 was correctly determined by the respondents. However, where the petitioners made a bona fide attempt to remit the determined sum within the extended Scheme period and the payment failed for a technical reason beyond their control, the substantive benefit of the Scheme could not be denied on procedural grounds. The petitioners were therefore entitled to avail the Scheme on payment of the determined amount with interest.</description>
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