Statutory compliance scheme deadlines must be strictly followed, and recovery can proceed even before interest and penalty are quantified.

The Voluntary Compliance Encouragement Scheme, 2013 was treated as a statutory scheme requiring strict compliance within the prescribed time, and no right to extension arose from failure to remit the declared amount within that period. On default, the revenue authorities could proceed with lawful recovery measures for tax dues, including interest and penalty, and pending quantification of interest and penalty did not bar garnishee or attachment action against available amounts. The writ challenge to refusal of extension was therefore unsustainable, while the recovery proceedings were not found illegal; the court directed quantification of the dues and issue of demand within the stipulated time.

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Issues: Whether the rejection of the request to extend time under the Voluntary Compliance Encouragement Scheme, 2013 was liable to be interfered with, and whether recovery proceedings including attachment could be pursued despite pending quantification of interest and penalty.

Analysis: The Scheme was treated as a statutory scheme requiring compliance within the time fixed by it. Failure to remit the declared amount within that period did not confer any right to seek extension. On non-compliance, the authorities were entitled to take steps for recovery of tax dues, including interest and penalty, in accordance with law. Pending quantification of interest and penalty did not preclude the department from initiating appropriate garnishee action against available amounts.

Conclusion: The challenge to the rejection of extension was not sustainable, and the recovery action was not found to be illegal. The petitioner was not entitled to substantive relief.

Final Conclusion: The writ petition was disposed of with a direction to the authorities to quantify the amount due and raise a demand within the stipulated time.

Ratio Decidendi: A statutory compliance scheme must be adhered to within the prescribed time, and on default the revenue authorities may proceed with lawful recovery measures even if interest and penalty are yet to be quantified.

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