2024 (6) TMI 1267

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....heme, 2019 (SVLDRS, 2019) can any proceedings be initiated under Section 129 (2) (c) of the Finance Act, 2019 without a finding that any material particular furnished by the declarant in the declaration is false. In our view, the answer is no. 3. Admittedly, petitioner had filed an application SVLDRS-1 on the GST portal under Section 125(f) of the SVLDRS, 2019 read with Rule 3 (d) of the SVLDRS Rules, 2019 under the category of voluntary disclosure for service tax matter in terms of Section 123 (d) of the Finance (No. 2) Act, 2019. 4. Admittedly, the declaration was processed, Form 2 and 3 were issued, the amounts determined to be payable under Form 3 has been paid and Form 4 certificate of discharge under Section 127(8) with respect ....

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....ble to be prosecuted under the indirect tax enactment with respect to the matter and time period covered in the declaration; (c) no matter and time period covered by such declaration shall be reopened in any other proceeding under the indirect tax enactment. (2) Notwithstanding anything contained in sub-section (1),- (a) no person being a party in appeal, application, revision or reference shall contend that the central excise officer has acquiesced in the decision on the disputed issue by issuing the discharge certificate under this scheme; (b) the issue of the discharge certificate with respect to a matter for a time period shall not preclude the issue of a show cause notice,- (i) for the same ....