Prathiba M. Singh, J. (Oral)

1. This hearing has been done through hybrid mode.

2. The present petition has been filed challenging the impugned order dated 30th June, 2023 passed by the Assistant Commissioner Division- Okhla, Central Goods and Service Tax (Delhi South) (hereinafter, 'the impugned order') by which a demand of service tax to the tune of Rs. 46,86,276/- under Section 73(2) of the Finance Act, 1944, has been confirmed against the Petitioner, along with certain penalties under Section 76(1) and Section 77(2) of the Finance Act, 1944. The petition also challenges the order dated 2nd March, 2020 passed by the Designated Committee, Sabka Vikas Legacy Dispute Resolution Scheme (hereinafter, 'SVLDR Scheme')

3. The petition has a history that deserves to be captured in the present order. During March to December, 2017 the Petitioner had filed certain refund applications under the CENVAT Credit Rules, 2004, for accumulated/ unutilised CENVAT credit. The credit being sought by the Petitioner was for the following period: