GST amnesty scheme: eligibility hinges on full tax payment and clarified treatment of appeal pre deposits and multi period notices.
Section 128A creates a GST amnesty waiving interest and penalty where taxpayers meet scheme conditions, but the treatment of appeal pre-deposits is unclear-specifically whether withdrawn pre-deposits can be treated as tax paid or whether taxpayers must pay full tax and seek refund separately. The Circular and related rules require payment of entire tax demands where notices cover multiple periods, including those outside the scheme, and mandate timely payment of interest and penalty for excluded periods, a position that may conflict with recent authority invalidating consolidated multi period notices. (AI Summary)

Pre-deposit credit uncertainty may limit benefit of Tamil Nadu tax settlement scheme without departmental clarification.
The Act permits eligible dealers to settle tax, interest and penalty liabilities by paying a specified percentage, with a waiver of accrued interest providing relief; however, ambiguity exists whether amounts paid as a pre-deposit in appeals can be credited against the settlement sum under Section 7, given that pre-deposits are treated as deposits not tax. Conflicting definitions of arrears of tax and disputed tax, together with an express restriction on adjustment or refund, and unclear treatment of demands revised after assessment, necessitate departmental clarification to effectuate the scheme's intent. (AI Summary)