Extended compliance time under legacy dispute resolution scheme treated Form-3 payment as a covered statutory requirement.

The article examines whether payment deadlines under the Sabka Vikas (Legacy Dispute Resolution Scheme), 2019 were extended by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. It explains that the payment obligation in Form-3 was treated as part of the statutory settlement process and that section 6 extended compliance time for covered indirect tax actions falling between 20.03.2020 and 29.09.2020 up to 30.09.2020. On that reading, delayed remittance was not treated as fatal, and settlement applications could be processed where payment was made within the extended period.

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Issues: Whether the time for payment of tax under the Sabka Vikas (Legacy Dispute Resolution Scheme), 2019 stood extended by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 so as to require acceptance of the appellants' delayed remittance and issuance of settlement certificate.

Analysis: The payment obligation under Form-3 under the Scheme was linked to the time fixed for completion of the statutory settlement process. Section 6 of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 extended, for the relevant indirect tax laws, the time limit for completion or compliance of actions falling between 20.03.2020 and 29.09.2020 up to 30.09.2020. Reading the provision liberally, the Court treated payment of the quantified amount in Form-3 as a covered compliance requirement. On that basis, the appellants' non-payment by the earlier dates was not treated as fatal, and their approach to the Court within the extended period was not held to suffer from delay and laches.

Conclusion: The appellants were entitled to remit the quantified tax dues with interest and have their settlement applications processed under the Scheme.

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