In a recent decision, the Bombay High Court sided with Astute Valuers and Consultants Pvt. Ltd., canceling tax demands from the Indian government. The court decided that the company did not have to pay extra interest and penalties after receiving a Discharge Certificate under the SVLDRS plan.
Astute Valuers, based in Mumbai, offers advisory services and is registered under the Finance Act, 1994. The company went through an audit for the years 2013-2018, which showed some differences. After this, they made payments based on the audit findings in March 2019.
On July 5, 2019, the government introduced the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, effective from September 1, 2019. Astute Valuers filed a statement under this plan on December 14, 2019, acknowledging tax dues of ₹21,03,943.
The company made a payment of ₹8,41,577.20 under the plan and received a Discharge Certificate on February 22, 2020. This certificate was meant to settle all tax dues.
"The issuance of the Discharge Certificate should have been the end of the matter," argued Mr. Raichandani, lawyer for Astute Valuers.
Despite the Discharge Certificate, the Central Board of Indirect Taxes and Customs sent notices in March 2021 and June 2022, asking for interest on late payments for previous years.
Judges M.S. Sonak and Advait M. Sethna ruled on December 12, 2025, that the demands were against the Finance Act, 2019. They stressed that the Discharge Certificate should completely settle the matter.
"The actions of the Respondents ought to be within the limits and scope of Article 265 of the Constitution," the judgment stated.
The court ordered the authorities to consider Astute Valuers' declaration under the right category, making sure the company gets the benefits of the SVLDRS scheme without any more payments.
This ruling highlights the importance of following legal rules and the finality of Discharge Certificates in tax disputes.
