Quantification of duty under the Sabka Vishwas Scheme requires final assessment by the cut-off date, not partial admission during investigation

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....Under the Sabka Vishwas Scheme, a liability admitted during enquiry or investigation was not treated as final quantification of duty by itself. Eligibility required the duty payable in the pending matter to be quantified on or before the statutory cut-off date, and a partial admission during investigation could not satisfy that requirement. On that basis, the rejection of the declaration was upheld because the tax liability had not been finally quantified by 30.06.2019. The hearing before the Designated Committee arose only after eligibility was established, so no prior hearing was required where the declarant was ex facie ineligible.....