Natural justice in tax settlement schemes requires a meaningful hearing, especially when lockdown disrupts the scheduled adjournment.

Under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, the designated committee must exercise its discretion on adjournments consistently with natural justice and afford an effective hearing where the estimated liability exceeds the declared amount. A hearing fixed during the COVID-19 lockdown could not realistically be treated as the final opportunity, and another date ought to have been granted. Because the impugned statement was issued without that meaningful hearing and without furnishing the adverse material relied upon, the decision was vitiated. The order was quashed and the matter remanded for fresh consideration with a hearing and a speaking order.

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Issues: Whether the petitioner was denied a meaningful opportunity of hearing before issuance of the statement under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, and whether the impugned order was liable to be set aside and the matter remanded.

Analysis: The Scheme and the Rules require the designated committee to issue an estimate, afford an opportunity of hearing where the estimated liability exceeds the declared amount, and deal with adjournment requests in a fair and judicious manner. The use of the word "may" in the proviso governing adjournment indicates discretion, but that discretion cannot be exercised rigidly so as to defeat natural justice. A hearing fixed during a nationwide lockdown occasioned by the COVID-19 pandemic could not realistically be treated as the only adjourned hearing date. In such exceptional circumstances, another hearing date ought to have been granted. Since the impugned statement was issued without affording such effective hearing, the decision was vitiated. The Court also noted that the adverse material relied upon was not furnished to the petitioner.

Conclusion: The petitioner was denied a proper opportunity of hearing and the impugned order was quashed. The matter was remanded to the designated committee for fresh consideration after granting hearing and passing a speaking order.

Ratio Decidendi: Statutory discretion to limit adjournments under a tax settlement scheme must be exercised consistently with natural justice, and an adjourned hearing fixed during an extraordinary impossibility such as a lockdown cannot be treated as a valid final hearing without granting another opportunity.

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