EVERSHINE ENTERPRISES vs UNION OF INDIA AND 2 ORS

3. ______________________________________________________ CORAM : M.S. Sonak & Advait M. Sethna, JJ. DATED : 3 November 2025 ORAL JUDGMENT (Per M.S. Sonak, J.):- 1. Heard learned counsel for the parties. 2. We issue Rule in this Petition and make the Rule returnable immediately at the request of and with the consent of the learned counsel for the parties. 3. The Petitioner seeks to quash the statement issued by the Respondents to form SVLDRS-3 dated 26 December 2019 (Exh.A) primarily on the ground that the amounts already recovered from the Petitioner or the amounts predeposited by the Petitioner were not adjusted in determining the amount which the Petitioner has been called upon to pay under 8-WP-3138-2022.DOCX SVLDRS-3. 4. On 13 June 2013, the Petitioner was served with a show-cause notice cum demand notice proposing to demand service tax of Rs.2,25,31,804/- for the period from 2008-2009 to 2011-2012. The Petitioner responded on 9 December 2013 in which he pointed out that the major portion of the demand had already been remitted before the issuance of the show- cause notice. After this, the Petitioner was issued another show-cause notice-cum-demand notice dated 28 March 2014, t