JUDGMENT

K.R.SHRIRAM, J. - Petitioner is a member of various stock exchanges including National Stock Exchange and Bombay Stock Exchange and undertakes trading in shares, currencies and derivatives instruments as a stock broker for its clients. Petitioner discharges service tax on the brokerage / commission received from the clients towards rendition of services of stock broking services to its domestic and foreign clients. Petitioner also undertakes trading on its own account as well.

2. In 2019, Government of India introduced a scheme called "Sabka Vishwas (Legacy Dispute Resolution) Scheme 2019 (the scheme) under Chapter V of the Finance Act, 2019 (Finance Act). The scheme was applicable to various enactments as mentioned under sec. 122 of the Finance Act and that included the Finance Act 2004, Finance Act 2007, Finance Act 2015 and Finance Act 2016. Under the scheme, all persons were eligible to make a declaration to settle under the Scheme except those specifically excluded under sec. 125 of the Finance Act. As per the scheme, the eligible person would make a declaration under the scheme, which shall be considered by the designated committee under sec. 126 of the Finance Act an