[2026:RJ-JD:9010-DB]

HIGH COURT OF JUDICATURE FOR RAJASTHAN AT JODHPUR D.B. Civil Writ Petition No. 691/2025 M/s Ganga Singh Palace, Ajmer Road, Nagaur (Raj.) Through Its Proprietor Smt. Santosh Devi Parihar W/o Rameshwar Lal Parihar, Aged About 50 Years, Resident Of Near Trimurti Secondary School, Ajmer Road, Nagaur (Raj).

----Petitioner Versus

1. Union Of India, Through The Secretary, Ministry Of Finance, Department Of Revenue, North Block, New Delhi.

2. The Commissioner Of Central Goods And Service Tax Cum Central Excise, G-105, New Basni Industrial Area, Near Diesel Shed, Jodhpur (Raj.)

3. The Joint Commissioner-Cum- Member, Svldrs (Sabka Vishwas (Legacy Dispute Resolution) Scheme) 2019, G- 105, New Basni Industrial Area, Near Diesel Shed, Jodhpur (Raj).

----Respondents Connected With D.B. Civil Writ Petition No. 21856/2024 M/s Ganga Singh Palace, Ajmer Road,nagaur Rajasthan Through Its Proprietor Smt. Santosh Devi Parihar Wife Of Shri Rameshwar Lal Parihar, Aged About 50 Years, Resident Of Near Trimurti Secondary School, Ajmer Road, Nagaur Rajasthan.

----Petitioner Versus

1. Union Of India, Through The Secretary Ministry Of Finance,department Of Revenue, North Block, New Delhi.

2. The Commissioner Of Central Goods And Service Tax Cum Central Excise, G-105 ,new Basni Industrial Area, Near Diesel Shed ,jodhpur Rajasthan.

3. The Joint Commissioner-Cum Member, Svldrs(Sabkha Vishwas (Legacy Dispute Resolution Scheme),2019 G- 105,new Basni Industrial Area,near Diesel Shed,jodhpur Rajasthan.

----Respondents For Petitioner(s) : Mr. Sheetal Kumbhat For Respondent(s) : Mr. Rajat Arora HON'BLE MR. JUSTICE ARUN MONGA HON'BLE MR. JUSTICE YOGENDRA KUMAR PUROHIT

Order(Oral)

18/02/2026 Per : Arun Monga, J

1. Petitioner is before this Court aggrieved against the action or inaction, as the case may be, of the respondent Department in denying it the benefit of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 (SVLDRS).

2. It is borne out that two show cause notices dated 18.09.2015 and 01.12.2017 were issued by the Service Tax Department alleging that the petitioner, being a service provider, was engaged in rendering “Short Term Accommodation Service”, “Restaurant-cum-Bar Services”, “Mandap Keeper Service”, and “Business Auxiliary Service” during the period from April 2010 to January 2015 and February 2015 to March 2016, respectively. It was stated therein that the petitioner had failed to discharge service tax liability amounting to Rs. 14,67,059/- and Rs.

6,39,954/- respectively.

2.1 The respondent authority adjudicated the aforesaid show cause notices and, vide two separate Orders-in-Original i.e. one dated 03.03.2017 and the other dated 31.05.2018 and confirmed the demands raised therein. The petitioner came to know of the initiation and culmination of the said proceedings only in September 2019, upon receipt of a recovery notice following the demise of her brother-in-law. Later on sometime, the husband of the proprietor suffered a heart attack and was hospitalized, resulting in considerable emotional distress to the family.

2.2 In the interregnum, the Government introduced the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, enacted under Chapter V of the Finance (No. 2) Act, 2019, with the objective of reducing pending litigation under erstwhile indirect tax laws, including the Service Tax regime.

2.3 The petitioner, seeking to avail the benefit of the Scheme, filed a declaration in Form SVLDRS-1, pursuant to which the respondent authority issued Form SVLDRS-3 determining the amount payable.

2.4 However, owing to the petitioner’s financial hardship arising from substantial medical expenses incurred for her husband’s treatment and severe business losses suffered during the COVID- 19 pandemic, the petitioner was unable to deposit the determined amount within the stipulated time.

2.5 Subsequently, after the easing of COVID-19 restrictions in January 2022 and upon gradual revival of her hotel business, the petitioner managed to deposit sums