Nature of Petition (Para 3):

Petition under Article 226 of the Constitution challenging rejection of SVLDR Scheme declarations due to alleged non-quantification of duty before 30 June 2019.

Background (Paras 4-7):

• Summons Issued (28 June 2018): Approximate service tax liability of ₹21.70 lakhs admitted by Petitioner.
• Tax Payments Made: ₹13 lakhs paid initially, later updated to ₹23.73 lakhs (15 April 2019).
• SVLDRS Declarations: Applications under “investigation, enquiry, or audit” category rejected twice due to alleged non-quantification before 30 June 2019.

Petitioner’s Arguments (Paras 8-9):

• Duty was quantified in the statement recorded on 28 June 2018.
• Petitioner was willing to rectify any discrepancies and pay ₹28,72,603/- with interest.

Respondents’ Position (Para 9):

• Argued duty was quantified post-30 June 2019 in a show-cause notice.
• Conceded court precedents favoring the Petitioner’s position.

High Court's Analysis (Paras 10-13):

• Quantification: Petitioner’s admission of liability on 28 June 2018 amounted to quantification.
• Disqualification Provision (Section 125(1)(e)): Does not apply where quantification occurred before 30 June 2019.

Rectification under Section 126 (Paras 14-15):

• Authorities could have corrected the declaration figures instead of outright rejection.
• Court upheld Petitioner’s willingness to rectify discrepancies and pay interest.

Acts and Sections Discussed

1. Finance Act, 1994
   • Section 83: Issuance of summons for tax inquiries.
2. SVLDR Scheme, 2019:
   • Section 125(1)(e): Eligibility criteria for quantification before 30 June 2019.
   • Section 126: Power to verify and adjust declarations.
   • Section 127: Issuance of final certificates.

Ratio Decidendi:

• Admission of liability in a recorded statement suffices as “quantification” under the SVLDR Scheme.
• Authorities must facilitate rectification instead of dismissing declarations.
• Courts prioritize the Scheme’s purpose to resolve disputes amicably over procedural rigidity.

Subjects:

Taxation, SVLDR Scheme, Judicial Interpretation of Eligibility.

Tax Dispute Resolution, GST Compliance, Writ Petition, High Court Judgment, Quantification of Duty.