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    <title>2022 (10) TMI 1199 - KARNATAKA HIGH COURT</title>
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    <description>A pre-cut-off written admission or quantification of service tax liability can satisfy the SVLDRS quantification requirement even if audit or investigation remains pending. The Scheme and clarificatory circulars treat a written communication admitting duty liability, including one made during enquiry, investigation or audit, as sufficient quantification for eligibility. Pendency of audit or investigation by itself does not defeat the claimant where the liability had already been quantified before 30 June 2019. The earlier dismissal as infructuous did not create res judicata because no issue had been finally determined. The rejection of the SVLDRS claim was therefore unsustainable and the matter was remitted for fresh consideration.</description>
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      <link>https://www.taxtmi.com/caselaws?id=309491</link>
      <description>A pre-cut-off written admission or quantification of service tax liability can satisfy the SVLDRS quantification requirement even if audit or investigation remains pending. The Scheme and clarificatory circulars treat a written communication admitting duty liability, including one made during enquiry, investigation or audit, as sufficient quantification for eligibility. Pendency of audit or investigation by itself does not defeat the claimant where the liability had already been quantified before 30 June 2019. The earlier dismissal as infructuous did not create res judicata because no issue had been finally determined. The rejection of the SVLDRS claim was therefore unsustainable and the matter was remitted for fresh consideration.</description>
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