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2025 (1) TMI 547

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..... that the petitioner was in arrears of tax for a sum of Rs. 64,32,402/-. The declaration filed by the petitioner in SVLDRS 1 was also acknowledged. Later the respondent issued Form SVLDRS 3 dated 28.02.2020. It appears that after the receipt of the SVLDRS 3 dated 28.02.2020, the petitioner has also paid the tax amount pursuant to which SVLDRS 4 has been issued to the petitioner which is a final Discharge Certificate as is contemplated under Section 127 of the Finance Act No.2 Act, 2019 read with Rule 9 of the Saba Viswas (Legacy Dispute Resolution) Scheme, 2019. After the Discharge Certificate was issued, the Department had issued a Notice dated 07.02.2022 bearing Reference C.No.V/15/05/2020 Adj.Ch.Outer, wherein, a reference is made to the .....

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..... Sixty Five Thousand Eight Hundred Twenty Two Only] as detailed above, should not be demanded from them towards Service Tax payable on taxable services provided by them under proviso to Section 73(1) of the Finance Act, 1994 [as amended]; (v) Interest at the appropriate rate should not be demanded from under Section 75 of the Finance Act, 1994 [as amended), on the amount as mentioned in Sl. No.(iv) above. (vi) Penalty should not be imposed on them under Section 77 of the Finance Act, 1994 [as amended]; (vii) Penalty should not be imposed on them under Section 78 of the Finance Act, 1994 [as amended); (viii) an amount of Rs. 10,67,654/- [Service Tax: Rs. 10,30,841/- + EC Rs. 15,688/- + SHEC Rs. 7,844/- + SB Cess. Rs. 7,572/- + KK Cess: 5,709/ .....

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..... empted to settle the dispute and had filed a declaration in Form SVLDRS 1 stating that the petitioner was in arrears of tax for a sum of Rs. 64,32,402/-. The declaration filed by the petitioner in SVLDRS 1 was also acknowledged. Later the respondent issued Form SVLDRS 3 dated 28.02.2020. It appears that after the receipt of the SVLDRS 3 dated 28.02.2020, the petitioner has also paid the tax amount pursuant to which SVLDRS 4 has been issued to the petitioner which is a final Discharge Certificate as is contemplated under Section 127 of the Finance Act No.2 Act, 2019 read with Rule 9 of the Saba Viswas (Legacy Dispute Resolution) Scheme, 2019. 4. After the Discharge Certificate was issued, the Department had issued a Notice dated 07.02.2022 b .....

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