TaxTMI 
TaxTMI 
2026 (6) TMI 1105
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....ce tax department for providing taxable service namely Works Contract Service. However, the service tax liability was not discharged. The appellant filed under Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 (SVLDRS) vide application dated 31.12.2019 while self declaring their liability under the category of voluntary disclosure of the said scheme with respect to an amount of Rs.2,90,031/-. The said application was accepted and SVLDRS-3 form dated 30.01.2020 in terms of Rule 7 of the Sabka Vishwas (Legacy Dispute Resolution) Scheme Rules, 2019 was issued to the appellant. The appellant was required to pay the amount mentioned in said SVLDRS-3, electronically within a period of 30 days from the date of its issuance. However, the appel....
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....ter with respect of SVLDRS, 2019 is referred and following decisions have also been relied upon: (i) M/s. LG Chaudhary Vs. Union of India reported as 2022 (10) TMI 631 - Gujarat High Court (ii) M/s. Balaji Services and M/s. Balaji Publicity Vs. Union of India and Ors. reported as 2021 (10) TMI 435 - Madhya Pradesh High Court (iii) M/s. Win Power Engineering (P) Ltd. Vs. The Designated Committee Sabka Vishvas Legacy - Madras High Court reported as 2022 (12) TMI 603 - Madras High Court (iv) Capgemini Technology Services India Ltd. Vs. The Union of Inida - Bombay High Court reported as 2020 (10) TMI 3 - Bombay High Court (v) M/s. Jai Guru Cables Vs. The principal Chief Commissioner of GST & Central ....
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....cal Engineering Vs. Designated Committee, Sabka Vishwas Legacy Dispute Resolution Scheme (SVLDRS), Tirunelveli reported as 2022 (12) TMI 824 - Madras High Court and Union of India & Ors. Vs. Dharmendra Textile Processors & Ors. reported as 2008 (9) TMI 52 - Supreme Court has also been relied upon. CBIC Circular No. 1071/4/2019 dated 27.08.2019 has also been referred. With these submissions and impressing upon no infirmity in the order under challenge, appeal is prayed to be dismissed. 5. Having heard both the parties and perusing the records, foremost from the circular dated 27.08.2019 is perused, It is observed that the SVLDRS, 2019 was introduced and remained operationalized for the period from September 2019 to 31 December 2019. Dispu....
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....e are capable of one construction only then it would not be open to the courts to adopt any other hypothetical construction even on the ground that such construction is more consistent with the alleged object and policy of the act. In applying the rule of plain meaning any hardship and inconvenience cannot be the basis to alter the meaning to the language employed by the legislation. The Hon'ble Supreme Court in the recent judgment dated 30.07.2018 in the case of Commissioner of Customs (Import) Mumbai Vs. Dilip Kumar and Company and Others reported as 2018-TIOL-302-SCCUS-CD has held that the benefit of ambiguity, if any, in the statute cannot be extended in favour of assessee when it is the case of exemption notification or the legislation....
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....ar problems arising in future. But, from the very nature of things, it is impossible to anticipate fully the varied situations arising in future in which the application of the legislation in hand may be called for, and, words chosen to communicate such indefinite referents are bound to be in many cases lacking in clarity and precision and thus giving rise to controversial questions of construction. The process of construction combines both literal and purposive approaches. In other words the legislative intention le., the true or legal meaning of an enactment is derived by considering the meaning of the words used in the enactment in the light of any discernible purpose or object which comprehends the mischief and its remedy to which the e....