Judgment

KAPADIA, J.

( 1 ) THESE appeals by special leave have been filed against an additional direction given by the Gujarat High Court vide judgment dated 25. 9. 2002 holding the appellant liable to pay interest under the Kar vivad Samadhan Scheme, 1998 (for short "the Scheme") on the tax arrears to be determined by the designated authority (for short "da" ).

( 2 ) THE appellant filed a writ petition in the gujarat High Court against the rejection of the declarations made by the assessee under the said Scheme.

( 3 ) BY the impugned judgment, the High court held that the declarations filed by the appellant herein were competent as the assessees revision applications were pending on the date of filing of the declarations. The department was, therefore, directed to entertain the declarations, to determine the amount payable and to grant a certificate under Section 90 (1 ).

( 4 ) THE decision of the Gujarat High Court dated 25. 9. 2002 was challenged by the department before this Court vide civil appeal no. 4411 of 2003. [jt2005 (8) SC 50] by judgment pronounced today by this court, we have upheld the decision of the gujarat High Court in holding that the declarations filed by the as