CESTAT Dismisses Appeals as Legal Heirs Settle Tax Dispute Under SVLDR Scheme [Read Order]

The Chennai bench of the Customs, Excise and Service Tax Appellate Tribunal (CESTAT) has dismissed four service tax appeals filed by the legal heirs of late A. Kulandaivel, proprietor of A.K. Engineering & Associates, after the dispute was settled under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019.

The appeals were filed by Padmini, K. Ramesh, K. Jegadeesan and Arayee, all legal heirs of the deceased proprietor, challenging a 2015 order passed by the Commissioner of Central Excise (Appeals-I), Salem. During proceedings, their consultant R. Balagopal informed the tribunal that the matter had been resolved under the SVLDR scheme, with the tax liability already discharged.

The department's authorized representative Shri Harendra Singh Pal confirmed that the revenue authorities had accepted the settlement and issued a discharge certificate in Form SVLDRS-4 to the appellants. This certificate serves as conclusive proof of resolution under the government's amnesty scheme for legacy tax disputes.

Judicial Member Ajayan T.V. and Technical Member Vasa Seshagiri Rao noted that once the SVLDR scheme's benefits are availed and a discharge certificate is issued, the appeals must be treated as withdrawn under Section 127(6) of the Finance Act, 2019. The bench accordingly dismissed all four appeals as deemed withdrawn.

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The SVLDR scheme, introduced in 2019, provides a one-time settlement opportunity for pending tax disputes by offering substantial relief in penalties and interest. In this case, the legal heirs of the deceased proprietor chose to settle the service tax dispute rather than continue prolonged litigation.

The tribunal's order brings closure to the long-pending tax dispute that had continued even after the original appellant's death. CESTAT Bench pronounced the dismissal order in open court, upholding the finality that comes with settlement under the SVLDR scheme.

This case demonstrates how the government's dispute resolution mechanism is helping clear legacy tax cases, even those involving deceased assessees, by providing a practical settlement route outside the regular judicial process. The tribunal's decision respects the finality of such settlements while disposing of the connected appeals.

To Read the full text of the Order CLICK HERE

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