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BOMBAY HIGH COURT
M.S. Sonak, Jitendra Jain, JJ
Kaarya Facilities & Services Ltd – Appellant
Versus
Union of India – Respondent
| Table of Content |
|---|
| 1. eligibility under svldrs reliant on due quantification. (Para 3 , 4 , 6 , 12) |
| 2. court observes applicable eligibility criteria for tax scheme. (Para 5 , 7 , 9) |
| 3. court emphasizes taxpayers' appropriate liability quantification. (Para 10 , 11 , 13) |
| 4. final ruling for taxpayer's advantage, subject to interest conditions. (Para 16 , 17 , 18) |
DATED : 09 JUNE 2025 ORAL JUDGMENT :(Per M. S. Sonak, J.)
1. Heard learned counsel for the parties.
2. Rule. The rule is made returnable immediately at the request and with the consent of the learned counsel for the parties.
3. The Petitioner challenges the rejection of its Application under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 (“the SVLDRS Scheme”) and the consequent orders including show cause notice dated 23 February 2021, on various grounds, including inter-alia, non-consideration of CBIC Circular dated 27 August 2019, and the answers to the Frequently Asked Questions (FAQs), prepared by the Department on 24 December 2019.
4. At the outset, Mr Mishra, the learned counsel for the Respondents, raised the issue of delay and laches. He pointed out that the impugned rejection was communicated to the Petitioner o
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