The petitioner challenged rejection of its SVLDR Scheme application on the ground that quantification occurred after the cut-off date. The factual background showed that service tax liability was admitted during investigation prior to the cut-off date, though a higher figure was mentioned later in the show cause notice.

The Court held that benefit of the Scheme cannot be denied merely because a higher figure was mentioned by way of abundant caution. Since liability stood quantified before the cut-off date, rejection of the application was unsustainable. The rejection order was quashed.