2024 (9) TMI 1839

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....rovisions of the Finance Act, 1994. For the period from 01-10-2008 to 30-06-2010, the petitioner was assessed to pay service tax of Rs.1,41,97,591/- and a penalty of Rs.1,41,97,591/- together with interest payable thereon. Ext.P1 is the order dated 24-03-2017 adjudicating the aforesaid liability on the petitioner. A Dispute Resolution Scheme known as 'Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019', was introduced by the Central Government for settling disputes with assessees like the petitioner. The petitioner sought to avail the benefit of the scheme for settling the dispute leading to the issuance of Ext.P1 order. The petitioner was accordingly issued with a statement under the scheme (Form No.SVLDRS-3) permitting the petitioner ....

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....ounsel appearing for the respondents, I am of the view that the petitioner is entitled to succeed. The fact that the petitioner was entitled to settle the disputes leading to Ext.P1 order by opting for settlement under the scheme is not disputed. It is also not disputed that the petitioner had filed an application for settling the dispute under the provisions of the scheme and had also been issued a declaration permitting the petitioner to settle the dispute by paying a sum of Rs.85,18,554.60/-. It is true that, going by the provisions of Section 127 of the Finance (No.2) Act, 2020, the amount had to be paid on or before 30-06-2024. It cannot be disputed that towards the end of Mach 2020, the entire country was placed under lockdown on acco....