Petitioner Ineligible for Scheme Due to Audit Timing; Court Quashes Orders for Lack of Proper Notice and Hearing.

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....Eligibility of the petitioner to make a declaration under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2015 (SVLDRS) and the appropriation of the amount quantified in the audit report from the eligible refund claimed by the petitioner. The court held that the petitioner was ineligible to make a declaration under SVLDRS as the audit was initiated before 30.06.2019, and the amount of duty involved was not quantified on or before that date, as per Section 125(1)(e) of the Scheme. Regarding the appropriation of the refund, the court ruled that the respondent authority was not justified in adjusting the outstanding dues quantified in the audit report from the refund claim without issuing a show-cause notice or providing an opportunity f.........