Tax Settlement Scheme: 60% Waiver Applies to Full Disputed Amount Without Pre-deposit Deduction Under Amnesty Rules

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....HC ruled on tax settlement scheme interpretation regarding admitted versus disputed tax amounts. Settlement Officer erroneously deducted pre-deposit from disputed amount before applying 60% waiver under scheme. On Rs. 5,94,03,043 disputed amount (difference between determined tax Rs. 6,27,82,418 and admitted tax Rs. 33,79,374), petitioner was entitled to 60% waiver on full disputed sum without pre-deposit adjustment. Court set aside appellate authority's order, directed recalculation of settlement amount without deducting Rs. 49,00,000 pre-deposit from disputed amount before applying waiver. Ordered refund of excess amount with 6% interest per annum from deposit date until refund. Court emphasized liberal interpretation of beneficial tax legislation per precedent.....