Court finds rejection of SVLDRS-1 form valid due to non-quantification of tax liability before the stipulated deadline.
Ahmedabad, June 18, 2026 — In a significant decision, the Gujarat High Court has dismissed a writ petition filed by Planet Automative Pvt. Ltd., which sought relief under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019. The petitioners, an authorized dealer of Hyundai cars, contested the rejection of their Form SVLDRS-1 by the Designated Committee, arguing that their tax liability had been quantified before the cut-off date of June 30, 2019.
The bench, comprising Justices A.S. Supehia and Vaibhavi D. Nanavati, concluded that the quantification of tax liability was not completed before the deadline, rendering the petitioners ineligible for the benefits of the scheme. The court emphasized the scheme's requirement that tax liabilities must be quantified in writing by the specified date for eligibility, which was not met in this case.
Planet Automative Pvt. Ltd. was initially investigated for unpaid service tax amounting to Rs. 25,73,507. However, further scrutiny revealed an outstanding liability of Rs. 1,83,11,330, leading to a show-cause notice and eventual imposition of penalties and interest by the authorities.
The petitioners contended that their admission of the initial liability during the investigation should suffice for quantification under the scheme. However, the court clarified that such admissions do not equate to the final quantification required by law, especially when the liabilities are reassessed and increased post-investigation.
Additionally, the court addressed the petitioners' claim that they were denied an opportunity of hearing. It was noted that under Section 127 of the scheme, such opportunities are contingent upon eligibility, which was absent in this case due to the unmet quantification prerequisite.
The judgment underscores the strict adherence required to the procedural mandates of the Sabka Vishwas Scheme, reinforcing that only fully quantified liabilities by the prescribed date qualify for settlement and relief under the scheme.
Bottom line:-
Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 - Tax liability must be quantified on or before 30.06.2019 for eligibility under the Scheme - Admission of partial tax liability during investigation does not suffice for quantification under the Scheme.
Statutory provision(s):
- Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 Sections 121(r), 123(c), 125(1)(e), and 127
Planet Automative Pvt. Ltd. v. Union of India, (Gujarat)(DB) : Law Finder Doc id # 2931173
