Manual processing required where PAN duplication blocked access to a time-bound tax settlement scheme.

A writ of mandamus was issued where two PAN numbers linked to a deceased assessee prevented electronic filing under the Direct Tax Vivad Se Vishwas Scheme, 2020. The Court held that computer systems are only facilitators and cannot obstruct statutory or scheme-based compliance. When automation creates a technical barrier, the tax authorities must manually accept and process the applications so that a time-bound settlement scheme is not defeated. The respondents were directed to merge or transfer the PAN-linked data and to consider the applications in accordance with the prayers made.

---

---

Issues: Whether a writ of mandamus should issue directing the tax authorities to merge or transfer PAN-linked data and appeals and to accept and process the petitioner's applications under the Direct Tax Vivad Se Vishwas Scheme, 2020 manually despite the computer system not accepting them.

Analysis: The relief sought arose from the existence of two PAN numbers in relation to the deceased assessee, which prevented electronic acceptance of the applications. The Court held that computer systems are only facilitators and cannot obstruct statutory or scheme-based compliance. Where the automated system creates an impediment, the authorities must resort to manual acceptance and processing so that a time-bound scheme is not defeated.

Conclusion: The writ petition was allowed and a mandamus was issued to the respondents to act in terms of the prayers for merging or transferring the PAN-linked data and for accepting and processing the applications.

Final Conclusion: The petitioner was granted effective access to the scheme relief by requiring the revenue authorities to use a manual mode of processing if necessary, so that technical constraints did not defeat consideration of the applications.

---