RG Studios v. Union of India & Ors.

What happened

Before the 30 June 2019 scheme cutoff, the service-tax department wrote to RG Studios’ bank identifying approximately ₹44.28 lakh of outstanding tax and directing a lien. Its later Sabka Vishwas declaration was rejected because that quantification was communicated to the bank, rather than directly to the firm.

Questions before the court

• Can a written third-party bank recovery communication quantify an amount payable for the legacy dispute scheme?

Why the court ruled this way

The written lien letter identified the tax and directly affected the taxpayer’s account. Section 121(r) concerns communication of the quantified tax amount; addressing it to the bank did not prevent it from serving that purpose.

Controlling point

The written lien letter identified the tax and directly affected the taxpayer’s account. Section 121(r) concerns communication of the quantified tax amount; addressing it to the bank did not prevent it from serving that purpose.

Order and next steps

The rejection was set aside and the writ petition allowed in the specified prayer clauses, without costs.

Practical implications

The operative result is case-specific: The rejection was set aside and the writ petition allowed in the specified prayer clauses, without costs. Apply it within the court’s stated limit: The decision rests on a pre-cutoff written quantified demand; it does not dispense with the scheme’s other eligibility requirements.

Limits of this ruling

• The decision rests on a pre-cutoff written quantified demand; it does not dispense with the scheme’s other eligibility requirements.