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2023 (6) TMI 150 - HC - Service TaxValidity of SVLDRS-3 filed - amount in arrears - Rule 2(b) of Sabka Vishwas (Legacy Dispute Resolution) Scheme Rules, 2019 - It is submitted that, as SVLDRS-3 impugned in the present case has not recorded reasons for discarding the objections raised under SVLDRS-2A, it is apparent that the Authority has rejected the contentions which are apparently contrary to law in light of the submissions made and requires to be set aside. HELD THAT:- The said Form does assign any reason to reject the objections raised in SVLDRS-2A. Accordingly, the manner of consideration is not evident except for the conclusion. Prima facie, there appears to be ground for reconsideration of the contentions raised with an open mind, despite the conclusion already having been arrived at. The Authority to take note of the contentions and observations passed and to re-look into the matter. The Authority to keep in mind the scope of Section 126 read with Rule 6 of Sabka Vishwas (Legacy Dispute Resolution) Scheme Rules, 2019 and reconsider the matter. If SVLDRS-2A has a column 'Reasons for Disagreement' and the assessee has detailed such reasons, the authority ought to have assigned at least brief reasons in the remarks column in SVLDRS-3 while deciding on the quantification and rejecting the 'Reasons for Disagreement'. The matter is remitted to the Authority for reconsideration.
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