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2023 (4) TMI 771

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..... Dispute Resolution Scheme), 2019 - It is the contention of petitioner that due to reasons beyond his control [Covid-19 pendemic], the petitioner could not avail the benefit under said scheme by depositing the said amount before the last date - HELD THAT:- The SVLDRS scheme is a complete code in itself. It is trite law that in tax jurisprudence, any provision relating to concession/discount/rebat .....

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..... SHRI JUSTICE VIRENDER SINGH PETITIONER: SHRI SANJAY MISHRA ADVOCATE ORDER This petition has been filed by an assessee for seeking direction to deposit the discounted amount of tax to the tune of Rs.17,29,494/- under the Sabka Vishwas (Legacy Dispute Resolution Scheme), 2019 (for short, the SVLDRS-3) as per the quantification made by the Designated Committee under the said scheme. .....

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..... habad High Court held thus: It is an admitted fact that the petitioner did not deposit the amount under the Scheme within the time limit provided under the Scheme i.e. within 30 days. In that view of the matter, the High Court has rightly refused to grant relief to the petitioner for extension of the period to make the deposit under the Scheme. It is a settled proposition of law that a .....

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..... s, to relieve him of tax liability must establish clearly that he is covered by the said provisions and, in case of doubt or ambiguity, the benefit of it must go to the State. 3.2 The same view was followed in B.P.L. Ltd. Vs. CCE (2015) 13 SCC 220 wherein the Apex Court held thus: 21. We approve that the aforesaid reasoning and rationale given by the Tribunal in coming to the conclusion th .....

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