JUDGMENT :

1. Heard Shri Nishant Mishra, learned counsel for the petitioners and Shri Ramesh Chandra Shukla, learned counsel for the Revenue. Shri Shukla has placed on record the written instructions received by him. The same has been marked as ‘X’ and retained on record.

2. Present petition has been filed to challenge the estimate furnished to the petitioners on the Form SVLDRS-2 dated 04.12.2019, under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 (hereinafter referred to as 'the Scheme'), to the extent, the Estimate Amount Payable ('EAP' in short) has been determined at Rs. 70,11,055.50 against total disputed ‘tax dues’ taken at Rs. 1,40,22,111/-. According to the petitioners, the net EAP amount should have been computed at Rs. 15,37,816.00 against the total disputed ‘tax dues’ Rs.80,75,626/- only, after adjusting the amount of Rs. 25,00,000/- pre-deposited by the petitioners to maintain their appeals, filed earlier. A further consequential mandamus has been sought, effectively to issue the final SVLDRS-3, etc. Last, challenge has been raised to the adjudication order dated 30.12.2019 passed, pending the proceedings under the Scheme.

3. Undisputedly, the petitioners we