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Karan Singh vs Designated Committee Sabka Vishwas ... on 22 February, 2021

46. The observation in Karan Singh v. Designated Committee Sabka Vishwas Legacy Dispute Resolution Scheme &Anr. (supra) must also be read in their context. The Court had explained that the amount mentioned in the communication issued by the taxpayer could not alone be the measure for interpretation of the concept of quantification. The duty liability would also require to be determined by the Department. However, the said observations cannot be read to mean a final determination by the Department or a determination that is reflected in any written communication issued by the Department. It would suffice that the Department does not contest the tax dues as quantified by the taxpayer in its communication. As noted above, Section 123(c) of the Finance Act (No.2), 2019 is only applicable where enquiry, audit or investigation is pending. There is no question of final determination by the Department prior to conclusion of the said proceedings. Thus, the Revenue's contention that the expression "quantified" under Section 121(r) of the Finance Act (No.2), 2019 would necessarily mean the duty as finally determined by the Department for the purpose of Section 123(c) of the Finance Act (No.2), 2019 is unmerited."
Delhi High Court Cites 9 - Cited by 3 - Full Document

Chaque Jour Hr Services Pvt. Ltd. vs Union Of India & Ors. on 31 August, 2020

41. The decision in Chaque Jour HR Services Pvt. Ltd. v. Union of India (supra) is of no assistance to the Revenue in the facts and circumstances of this case. There is no cavil with the proposition that admission of part of dues would not qualify as "tax dues" for the purpose of Section 123(c) of the Finance Act (No.2), 2019; under Section 123(c) "tax dues" would mean the entire amount of duty payable under indirect tax enactment as quantified.
Delhi High Court Cites 14 - Cited by 11 - S Narula - Full Document
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