Delayed compliance under a tax amnesty scheme may be examined through representation, with administrative consideration ordered.

A delayed remittance under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 was treated as a matter requiring administrative consideration rather than direct substantive relief. The petitioner had substantially complied with the Scheme, and the only default was late payment of the amount quantified in Form 3. In view of the difficulties faced by declarants in meeting the prescribed timeline, the Court permitted the petitioner to submit a representation to the Board and directed the Board to decide it within the stipulated time. The merits of entitlement under the Scheme were not adjudicated.

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Issues: Whether the petitioner should be permitted to make a representation to the Board for consideration of acceptance of the delayed remittance quantified under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019.

Analysis: The petitioner had substantially complied with the Scheme and the only default was the belated remittance of the amount quantified in Form 3. The Court noted that the matter required consideration by the Board, particularly in light of the difficulties faced by declarants in making payment within the prescribed time. Instead of granting substantive relief on the Scheme claim, the Court directed the petitioner to approach the Board with a representation and required the Board to pass appropriate orders within a fixed time.

Conclusion: The petitioner was permitted to make a representation to the Board, and the Board was directed to consider it and pass orders within the stipulated time.

Final Conclusion: The writ petition was closed by directing administrative consideration of the petitioner's request, without adjudicating the merits of entitlement under the Scheme.

Ratio Decidendi: Where the dispute concerns delayed compliance under a fiscal amnesty scheme and the matter requires policy-level or administrative examination, the Court may direct representation and consideration rather than grant direct substantive relief.

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