Madras High Court: SVLDRS Relief is Not Available for Voluntary Disclosure Where Tax is Admitted in Returns

The Madras High Court has ruled that taxpayers cannot claim benefits under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 (SVLDRS) if they had already filed returns admitting the tax liability.

In the case of Taufiq Manpower Pvt Ltd, the company filed an ST-3 return on June 5, 2018, acknowledging ₹1,86,158 in service tax. Later, it sought a reduced liability under SVLDRS, paid just ₹29,706, and mischaracterized the claim as “arrears.”

The Court held that once tax is admitted through a return, voluntary disclosure benefits are ineligible. Consequently, the discharge certificate was invalidated, and the refund was denied; however, the petitioner may appeal.