ORAL ORDER

“(i) Directing the 1^st Respondent to appropriate the payment of Rs. 19,79,491/- made by the petitioner on 18.06.2021 towards the total amount of service tax that was payable by it in order to avail the SVLDR scheme.

(iii) Thus, direct the 1^st Respondent to forthwith issue a discharge certificate in Form SVLDRS-4, thereby discharging the petitioner of the remaining statutory liabilities payable it vide the order-in-Original dated: 13.01.2020 bearing C.No.IV/16/235/2019 ADJ/AWD3 and order Sl.No.02.2020 (Annexure-‘A’) passed under the Service Tax Act ;

(v-a) Alternatively, permitting the Petitioner to file an appeal against the order-in-Original dated: 13.01.2020, bearing C.No.IV/16/235/2019 ADJ/AWD3 and order Sl.No. 02.2020 (Annexure- ‘A’), before the Commissioner (Appeals), and directing the said authority to consider the appeal on merits without raising the issue of limitation.”

3. In addition to reiterating the various contentions urged in the petition and referring to the material on record, learned counsel for the petitioner submits that the issue in controversy is directly and squarely covere