Immunity under VCES prevents reopening overlapping service tax liabilities; subsequent notices on the same subject matter are barred.

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....Where a declarant furnished details under the Voluntary Compliance Encouragement Scheme (VCES) and received an acknowledgement of discharge, the scheme grants immunity from penalty, interest and further proceedings in respect of the declared tax dues; consequently, any subsequent notice or recovery proceeding that seeks to assess or recover an identical liability or that overlaps even slightly with dues already discharged under VCES is barred. Applying the conclusive effect of the VCES acknowledgement, the impugned demand was set aside insofar as it sought recovery of tax already verified and settled under the scheme, entitling the declarant to consequential relief.....