2021 (2) TMI 1122

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....Services Tax (GST), on the ground that the same could not have been issued, being for the same matter and for the same period, within the meaning of Section 129(1)(c) of the Sabka Vishwas (Legacy Dispute Resolution) Scheme (SVLDRS), 2019. 2. The petition was entertained and notice thereof was ordered to be issued and pleadings have been completed. 3. We have heard the counsels. 4. The contention of the counsel for the petitioner is, (i) that the petitioner is in the business of undertaking works contracts relating to construction business; (ii) during the period from 2014-15 till 30th June, 2017, the petitioner provided works contract services to various parties including Charms India Pvt. Ltd. (CIPL) and New Okhla Industrial Development....

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....o pay 100% of the tax and not 50%, as asked from it in the earlier notice dated 23rd April, 2019. 5. The counsel for the petitioner has contended  that the impugned show cause notice has been premised on, the petitioner having not made a full disclosure before the first Show Cause Notice dated 23rd April, 2019. It is contended that the petitioner applied under the SVLDRS, not in the 'voluntary disclosure' category but under the 'litigation' category, the application having been made after the first show cause notice had been issued. He has thus argued that the ground of full disclosure having not been made, for issuing the second show cause notice, is available only in the category of 'voluntary disclosure' and not in the category of ....