2023 (10) TMI 505

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....e) of the Finance (No. 2), 2019 to file a declaration under the Sabka Vishvas (Legacy Dispute Resolution) Scheme, 2019. Further prayer is for issuance of direction to respondent No. 4 to accept the declaration dated 13.12.2019 (Annexure P-18) filed by the petitioner. 2. Learned counsel for the petitioner submitted that the petitioner was experiencing financial crunch in the business in the year 2017 and respondent No. 2 issued a letter dated 14.01.2019 (P-1), wherein it was brought to the knowledge of the petitioner that it has not made payment of tax in first quarter of the year 2017-18 and directed the petitioner to submit the documents. Thereafter, respondent No. 3 initiated an enquiry against the petitioner by issuing letter dated 24.0....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ntimated about the same to respondent No. 3, vide covering letter dated 27.04.2019 (P-11) This all entries were shown by the petitioner in its quarter return on 27.04.2019 (P-12) ending 30.06.2019. Thereafter, the respondent No. 3 issued a letter dated 13.05.2019 to the petitioner informing that on verification of service tax payment made by the petitioner after due date, the total interest liability comes to Rs. 27,66,189/- and the petitioner has paid interest amounting to Rs. 8,86,255/- and the petitioner was asked to pay the remaining amount of interest amounting to Rs. 18,79,734/- along with applicable penalty at the earliest. 3. At the very outset, learned counsel for the petitioner has shown copy of letter dated 16.03.2023 and the s....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... upon scrutiny, they observed that the petitioner has short paid interest of Rs. 18,79,934/- for the said period. Accordingly. letter dated 13.05.2019 (Annexure P-13) was written to the petitioner to deposit the short paid interest amounting to Rs. 18,79,934/- along with applicable penalty. 6. As per available records, the petitioner did not deposited the aforesaid amount as demanded vide letter dated 13.05.2019. Furthermore, no other tax was due beyond these letters. 4. The grievance of the petitioner before this Court is that since the letter dated 13.05.2016 was issued before 30.06.2019, the case of the petitioner could not be rejected under Sabka Vishvas (Legacy Dispute Resolution) Scheme, 2019 on the ground that investigation was ....