(1.) By this petition under Article 226 and 227 of the Constitution of India, the petitioner has assailed the correctness, legality and validity of Communication dtd. 12/10/2020, by which, respondents-authorities communicated the petitioner that the declarations vide SVLDRS-01 application filed under the category of 'Voluntary Disclosure' for relaxation of applicable interest and penalty in respect of declared service is not eligible under SVLDRS-2019. It was also communicated that SVLDRS-04 dtd. 7/2/2020 were issued erroneously. Therefore, SVLDRS applications having ARN Nos. - LD-3112190020439, LD-3112190020561 and LD-3112190020627 all dtd. 31/12/2019 are rejected and further that demand of Rs.16,40,026.00 stands outstanding as such.
(2.) The petitioner has also sought quashing of Letter dtd. 28/11/2019, Internal Audit Report dtd. 8/1/2021 and Show Cause Notice dtd. 8/1/2021.
(3.) Factual matrix, relevant and necessary for adjudication of the controversy involved in the present petition is stated infra.