Karasamadhana Scheme relief cannot be denied for portal limits or unexplained interest arrears when deposit remains unappropriated.

Applications under the Karasamadhana Scheme, 2017 could not be rejected for want of website filing where the portal did not allow adjustment of amounts already in deposit. The court treated the petitioner's earlier 30% deposit before the Appellate Authority as a colourless deposit, not appropriated to any specific head until finality of the appeal, so the revenue could not insist on an additional 10% interest payment as a precondition. It also held that the demand notice and assessment order showed interest formed part of the total demand, making refusal of scheme benefit on the ground of no separately demanded interest arrears untenable. The rejection was therefore unsustainable, and the applications had to be accepted subject to tax payment requirements.

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Issues: Whether the rejection of the applications under the Karasamadhana Scheme, 2017 for non-submission through the website and alleged non-payment of 10% interest arrears was sustainable.

Analysis: The petitioner had already deposited 30% of the arrears before the Appellate Authority, and that deposit could not be treated as appropriated towards any specific head until the appeal proceedings attained finality. On that basis, the deposit retained the character of a colourless deposit and the revenue could not insist upon an additional 10% payment as a precondition for availing the scheme. The inability to file the application through the website was also found unjustified because the system did not permit adjustment of the amount already lying in deposit. The demand notice and assessment order together showed that the interest component formed part of the total demand, so denial of the scheme benefit on the ground that no arrears of interest were separately demanded was held untenable.

Conclusion: The rejection of the applications was unsustainable, and the petitioner was entitled to have the applications accepted and to receive the benefit of the scheme, subject to satisfaction of the tax payment requirement.

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