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Court Clarifies SVLDRS Eligibility: Rectification Not an Appeal, Affects Tax Arrears Calculation for Settlement Approval.

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....SVLDRS - Recovery of arrears of tax in terms of Section 124(1)(c) of the Sabka Vishwas (Legacy Dispute Resolution Scheme Rules, 2019 in the Finance Act, 2019 - jurisdiction under Section 74 of the Finance Act, 1994 was invoked to rectify the mistake - The High court found that initiating a rectification proceeding under Section 74 cannot be equated with filing an appeal under Section 86 of the Finance Act, 1994. Therefore, the petitioner’s case could not be considered under the appeal category for SVLDRS relief, which necessitates a different calculation of the dues. - The court allowed the settlement under SVLDRS upon payment of the due amount and interest.....