Mandatory payment deadlines under a fiscal amnesty scheme cannot be extended after expiry when the scheme provides no such power.

Under the Sabka Viswas (Legacy Dispute Resolution) Scheme, 2019, payment had to be made by the prescribed extended deadline, and the petitioner's liability had already been quantified and communicated. The Court held that the scheme contained no provision authorising further extension of time, and once the period expired the scheme stood closed. As the petitioner did not dispute the demand, illness or payment difficulty could not justify judicial enlargement of the deadline on equitable grounds. The request for extension was therefore rejected, and the recovery proceedings remained undisturbed for non-compliance with the mandatory payment deadline.

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Issues: Whether the time for payment under the Sabka Viswas (Legacy Dispute Resolution) Scheme, 2019 could be extended after the last date for deposit had expired.

Analysis: The petitioner's liability under the scheme had been quantified and communicated, and the payment was required to be made by the extended deadline of 30.06.2020. The Court noted that the petitioner did not dispute the amount demanded. It further found that the scheme did not contain any provision enabling extension of time for making the prescribed deposit, and the scheme itself contemplated its closure on expiry of the prescribed period. On those admitted facts, the grounds of ill health or difficulty in making payment could not justify judicial extension of the scheme period.

Conclusion: The request for extension was rejected and the writ petition failed.

Final Conclusion: The recovery proceedings were left undisturbed because the petitioner did not comply with the mandatory payment deadline under the scheme.

Ratio Decidendi: Where a fiscal amnesty scheme prescribes a final date for payment and does not authorize extension, the Court cannot enlarge the time on equitable grounds after the scheme has expired.

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