Belated writ challenge to an expired settlement scheme was refused because no effective relief remained available.

A belated writ challenge to a tax determination under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 was not entertained because the explanation for delay was not accepted and the Scheme had already expired. With no practical scope for effective relief after the Scheme's cessation, the Court declined interference and dismissed the petition. The governing principle was that a late challenge to a determination under an expired scheme does not justify writ relief where no effective remedy remains.

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Issues: Whether the writ petition could be entertained and relief granted against the impugned determination under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 after the Scheme had expired and the petitioner had approached the Court belatedly.

Analysis: The petition challenged an order determining tax under the Scheme, but the writ was filed long after the impugned order and after the Scheme had ceased to exist. The explanation for the delay was not accepted. The Court also noted that, in view of the expiry of the Scheme, there was no practical scope for granting the relief sought. Reliance was placed on a similar earlier order in which a writ petition on the same issue had been dismissed.

Conclusion: The writ petition was not entertained and no relief was granted.

Final Conclusion: The challenge to the tax determination under the expired Scheme failed, and the writ petition was dismissed.

Ratio Decidendi: A belated challenge to a determination under a scheme that has already expired does not warrant interference where no effective relief can be granted.

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