2020 (10) TMI 208

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....LDRS 1 under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 ('Scheme') on the ground that only one declaration has been filed by the Petitioner, whereas Rule 3 (2) of the Sabka Viswas (Legacy Dispute Resolution) Rules, 2019 ('Rules') requires "a separate declaration to be filed for each case". 2. The brief facts for the purpose of the present writ petition are that four Show Cause Notices ('SCNs') were issued to the Petitioner covering a period from July, 2013 to December, 2015, which SCNs taken together demanded a duty amount of Rs. 66,70,553/- from the Petitioner. By a consolidated order dated 17th March, 2016 of the Additional Commissioner, Central Excise, the demands were confirmed. 3. Aggrieved....

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.... for each 'case'. The Explanation thereunder defines a 'case' as under "(a) a show cause notice or one or more appeal arising out of such notice which is pending as on the 30th June, 2019 or (b) an amount in arrears; or (c) an enquiry or investigation or audit where the amount is quantified on or before the 30th June, 2019; or (d) a voluntary disclosure". 9. It is, thus, seen in the present case that as on 30th June, 2019, the four SCNs were not pending. In fact, these had been adjudicated and one consolidated order was passed in the four SCNs by the Additional Commissioner, Central Excise. Likewise, one consolidated order was passed by the Appellate Authority in the combined appeal. Th....