SVLDRS Credit dispute of Legacy law
By J the App
Executive Summary
In a significant reaffirmation of substance-over-form in tax dispute resolution, the Madras High Court ruled that amounts already deposited, irrespective of accounting classification, must be credited while determining liability under the Sabka Vishwas Scheme.
Rejecting hyper-technical objections of the Department, the Court emphasized that procedural constraints, including system limitations, cannot override statutory intent.
The ruling strengthens taxpayer rights in legacy dispute settlements and reinforces purposive interpretation of amnesty schemes.
Questions of Law / Issues for Determination
• Whether payments made under “interest” or “other receipts” can be excluded while computing tax dues under SVLDRS...
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