Legacy Indirect Tax Disputes | CBIC

Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019: Relief, Eligibility & Current Status

Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 (SVLDRS) was a one-time dispute-resolution and amnesty mechanism for legacy Central Excise, Service Tax and specified pre-GST indirect-tax disputes.

Updated: 5 September 2026

Current status: SVLDRS is closed. It was not a permanent dispute-settlement scheme and no fresh declaration can be filed under it in 2026. The nationwide scheme closed on 30 June 2020; a later special extension applied to eligible taxpayers in the Union Territories of Jammu & Kashmir and Ladakh up to 31 December 2020.
Legal correction: Service Tax was governed by Chapter V of the Finance Act, 1994, not the Finance Act, 1944. SVLDRS itself formed part of the Finance (No. 2) Act, 2019 and the associated Rules, 2019.

What Was Sabka Vishwas (SVLDRS)?

SVLDRS was announced in the Union Budget 2019-20 and operationalised from 1 September 2019. It was designed to settle disputes relating to legacy Central Excise and Service Tax laws that had largely been subsumed into GST.

The scheme had two broad components:

  • Dispute resolution for eligible pending legacy-tax disputes; and
  • Amnesty for specified taxpayers making eligible disclosures of unpaid legacy tax.

Main Objectives

  • Liquidate pending legacy disputes under Central Excise, Service Tax and other specified enactments.
  • Allow eligible persons to declare unpaid tax dues.
  • Provide substantial tax relief depending on the category of dispute.
  • Waive interest, fine and penalty in eligible cases.
  • Provide immunity from prosecution after valid discharge, subject to the statute.
  • Reduce litigation arising from the pre-GST indirect-tax regime.

Categories of Cases Covered

Subject to the statutory conditions and cut-off dates, the scheme covered categories such as:

  • show-cause notices and appeals pending as on the relevant cut-off date;
  • enquiries, investigations and audits where the amount of duty had been quantified on or before 30 June 2019;
  • tax arrears where the demand had attained finality;
  • amounts admitted as payable in a return but not paid; and
  • eligible voluntary disclosures.

Who Was Not Eligible?

The statute excluded specified persons and categories, including cases where:

  • an appeal had been finally heard on or before 30 June 2019;
  • a show-cause notice had been finally heard on or before 30 June 2019;
  • the person had been convicted for the matter for which declaration was proposed;
  • the notice related to an erroneous refund;
  • an enquiry, investigation or audit was pending but the amount had not been quantified on or before 30 June 2019;
  • an application was pending before the Settlement Commission;
  • the declaration concerned specified petroleum or tobacco products excluded by the legislation; or
  • the case fell within a statutory bar applicable to voluntary disclosure.

Relief Available under SVLDRS

Category Tax Dues Relief
SCN / appeal / eligible enquiry, investigation or audit ₹50 lakh or less 70% relief from tax dues
SCN / appeal / eligible enquiry, investigation or audit More than ₹50 lakh 50% relief from tax dues
Tax arrears / amount in return but unpaid ₹50 lakh or less 60% relief from tax dues
Tax arrears / amount in return but unpaid More than ₹50 lakh 40% relief from tax dues
SCN for late fee or penalty only, where duty was paid or nil Applicable amount 100% waiver of late fee / penalty
Voluntary disclosure Disclosed tax dues No reduction in principal tax; other statutory benefits applied subject to conditions

In eligible cases, the scheme also provided waiver of interest and penalty and protection from prosecution in accordance with the Finance (No. 2) Act, 2019.

Important Restrictions

  • The amount payable under the scheme could not be discharged through input tax credit.
  • Amounts paid under the scheme were not available as input tax credit.
  • The payment did not create an input-tax-credit entitlement for the recipient of goods or services.
  • Amounts paid under the scheme were not refundable.
  • False voluntary disclosure could expose the declarant to proceedings within the statutory period.

Discharge Certificate and Effect of Settlement

After determination and payment of the amount payable under the scheme, the designated committee issued a discharge certificate in the prescribed form.

Subject to the statutory conditions, a valid discharge certificate gave finality to the settled matter by providing the reliefs and immunities specified in the scheme.

SVLDRS did not permit a taxpayer to reopen a settled matter merely because a more favourable legal position emerged later. The effect of a discharge certificate is governed by the scheme provisions and relevant judicial interpretation.

Final Scheme Results

Government reporting stated that SVLDRS received 1,89,225 declarations involving approximately ₹89,823 crore of tax dues and led to recovery of about ₹27,866 crore.

It was described by the Government as the best-performing indirect-tax dispute resolution scheme up to that time.

Current Position in 2026

No fresh SVLDRS declaration can be filed in 2026. Taxpayers with unresolved pre-GST Central Excise or Service Tax disputes must examine the remedies presently available under the applicable statute, appellate framework, recovery provisions, judicial decisions and any later Government settlement measure that may specifically apply.

The CBIC continues to maintain legacy Central Excise and Service Tax material, including the SVLDRS 2019 archive, for reference.

Key Points to Remember

  • SVLDRS was a one-time legacy-tax settlement scheme under the Finance (No. 2) Act, 2019.
  • It covered eligible Central Excise, Service Tax and specified legacy indirect-tax disputes.
  • Relief ranged from 40% to 70% of tax dues depending on category and amount.
  • Interest, fine and penalty were waived in eligible cases.
  • Valid settlement provided statutory immunity from prosecution, subject to conditions.
  • The nationwide scheme closed on 30 June 2020.
  • No new SVLDRS declaration can be filed in 2026.