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Priya Soparkar 2 wp 871-20

3. According to the petitioner, it is a partnership firm duly registered under the Partnership Act, 1932 engaged in the business of providing advertising and design services to its customers. Petitioner was registered as a service provider under the Finance Act, 1994.

4. Service tax authorities initiated investigation against the petitioner pertaining to payment of service tax for two periods i.e. for the period 1 st April, 2016 to 31st March, 2017 and again for the period 1st April, 2017 to 30th June, 2017.

5. It is stated that vide letter dated 18th June, 2019 issued by the petitioner to respondent No.3 petitioner stated about certain payments and claims for the year 2016-17 and admitted service tax liability of Rs.10,74,011.00 for the period 1st April, 2017 to 30th June, 2017.

6. In the meanwhile, Central Government introduced the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 Priya Soparkar 3 wp 871-20 (briefly 'the scheme' hereinafter) to bring an end to pending litigations under the earlier indirect tax regime which now stood subsumed under the Goods and Services Tax (GST).

9. Above rejection of the application (declaration) of the petitioner was without affording any opportunity of hearing to the petitioner. In the circumstances, petitioner submitted a representation dated 31st January, 2020 addressed to respondent No.5 stating that as per notice dated 21 st May, 2019 respondents themselves had quantified the service tax liability for the period 2016-17 at Rs.47,44,937.00. It was pointed out that all service tax dues for previous periods were duly paid reiterating the contention that petitioner was denied the benefits under the scheme without any opportunity of hearing. The above representation was filed requesting that an opportunity of hearing be provided to the petitioner. This was followed by subsequent representation Priya Soparkar 4 wp 871-20 dated 3rd February, 2020 addressed to respondent No.4. However, no decision has been taken by the respondents and grievance of the petitioner has remained unaddressed.

Priya Soparkar 5 wp 871-20 17 as previous liability was discharged by the petitioner. It is stated that petitioner vide the letter dated 18 th June, 2019 accepted this liability for the period 2016-17 and on its own quantified its liability for the period 1 st April, 2017 to 30 th June, 2017 at Rs.10,74,011.00 though petitioner did not submit necessary documents for verification and quantification of actual liability.