respondent-Department for a value of Rs.5,86,32,847/- and the petitioner has paid entire disputed tax and insofar as, penalty/interest is concerned, seeking waiver of the same, the petitioner intended to avail the benefits conferred under the Scheme, called as ''Sabkavishwas (Legacy Dispute Resolution) Scheme 2019''and accordingly, filed Application in Form I on 23.12.2019 and 27.12.2019. However, the petitioner, after the filing of such applications, was put to knowledge that the applications dated 23.12.2019 and 27.12.2019 were applied by the petitioner under the wrong category, ''Arrears'' and ''Voluntary Disclosure'', instead of ''Investigation/Audit'', that, in order to correct the discrepancy in categorizing under the Scheme, the petitioner subsequently filed fresh Application on 13.01.2020 under the correct category, i.e. ''Investigation/Audit'' and also sent a representation to the first respondent asking them to consider the applications dated 13.01.2020 and to record the previous applications dated 23.12.2019 and 27.12.2019 as withdrawn. However, the respondent rejected the applications dated 23.12.2019 and 13.01.2020 on the ground that the petitionerCompany is ineligible to avail the benefits under the Schemes, as there is ongoing investigation and the tax liability is not quantified till 30.06.2019.
