TMI Blog2021 (1) TMI 32X X X X Extracts X X X X X X X X Extracts X X X X ..... Show Cause Notice dated 9.12.2019. If there was quantification in terms of the Final Reminder as now asserted by the petitioner, in Form in SVLDRS-1 the petitioner should have mentioned in the relevant column the amount indicated in the Final Reminder dated 15.11.2018. The fact that the petitioner mentions the Tax liability/ Demand in Form SVLDRS-1 as 95,94,517/-, an amount which is quantified in terms of the Show Cause Notice dated 9.12.2019, shows that even according to the petitioner there was no quantification as of the prescribed date viz., 30.06.2019. This Court is not persuaded to conclude that there is any error in the impugned order rejecting the petitioner s form in Form SVLDRS-1 - Petition dismissed. X X X X Extracts X X X X X X X X Extracts X X X X ..... lling upon the petitioner to pay short payment and late fee as mentioned in this communication. The petitioner has paid certain amounts thereafter and the Offence Report in O.R. No.31/2018-19 is filed on 12.09.2018. In this Offence Report, the petitioner's liability is approximated in a sum of ₹ 99,00,000/-. The Offence Report is followed up with 'Final Reminder' dated 15.11.2018 calling upon the petitioner to pay short paid amount of ₹ 10,83,127/-. It is thereafter Show Cause Notice dated 9.12.2019 is issued calling upon the petitioner to show cause why, inter alia, a sum of ₹ 95,94,517/- should not be recovered as service tax, education cess and secondary and higher education cess payable on the taxable value and also le ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er has filed belated returns for the relevant year during the month of July-August 2018 admitting to certain liability but has not paid the declared amount. 5. The contention urged by Sri. Jeevan J. Neeralgi cannot be accepted for different reasons, and chiefly for the reason that this is not the reason for which the declaration is rejected, and rejection cannot be justified by reasons which are not mentioned in the order of rejection. Even otherwise, after the petitioner has filed his belated returns in ST-3 returns, the petitioner has made some payments and there are subsequent Communication resulting, inter alia with issuance of Final Reminder dated 15.11.2018. However, it is beyond cavil that a Tax Payer would be entitled to Tax Relief ..... X X X X Extracts X X X X X X X X Extracts X X X X
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