Legacy dispute settlement under amnesty scheme cannot be revived after the payment deadline lapses, despite equitable hardship claims.

The Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 required payment of the amount stated by the Designated Committee within the time fixed under clause 127(5). The Bombay High Court noted that the payment period had already been extended to 30 June 2020, but no further extension was granted. It held that a writ court cannot rewrite the scheme or add conditions not accepted by the declarant, and that pandemic-related hardship did not justify reviving a lapsed statement. Once the determined amount was not paid within the permitted period, the statement ceased to survive and could not be enforced on equitable grounds.

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Issues: Whether the petitioner could, in writ jurisdiction, be permitted to deposit the amount determined under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 after the expiry of the period prescribed by the scheme and after the statement issued by the Designated Committee had lapsed.

Analysis: The scheme was a one-time amnesty window for settlement of legacy tax dues and required payment of the amount specified in the Designated Committee's statement within the time fixed under clause 127(5). The time for payment had already been extended up to 30/6/2020, but no further extension was granted. The Court held that the pandemic and the extensions already granted did not justify rewriting the scheme, and that a writ court cannot add to or alter the conditions voluntarily accepted by a declarant. Once the determined amount was not paid within the permitted period, the statement ceased to survive and could not be revived on equitable considerations.

Conclusion: The petitioner was not entitled to any direction enabling payment after the lapse of the scheme period, and the plea to revive the lapsed statement was rejected.

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