Bona fide compliance under a fiscal amnesty scheme requires timely payment and prompt objection; belated claims fail after lapse.

Entitlement to benefit under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 failed because the petitioners did not establish bona fide pursuit of the statutory process or proof of effective remittance. The court noted that the plea of ignorance about rejection of payment was unsupported by material, while ordinary transaction alerts and the surrounding conduct undermined the claim. Rule 9 required payment and proof before issuance of a discharge certificate, yet no contemporaneous step was taken to secure the certificate and no timely objection was raised when later demand notices were issued. Prolonged silence and inaction, followed by a belated offer to pay with interest after the scheme had lapsed, defeated the claim for relief.

---

---

Issues: Whether the petitioners were entitled to the benefit of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 despite rejection of the remittance for mismatch in the amount paid and whether the writ petition disclosed any bona fides warranting acceptance of the delayed claim.

Analysis: The claim was founded on the assertion that the remitted amount was returned because of a minor mismatch and that the petitioners were unaware of the rejection due to a fixed deposit arrangement. The Court found no material beyond bare assertions to support absence of knowledge. It held that an account holder would ordinarily receive transaction alerts when a remittance is accepted or declined, and the surrounding conduct did not support the plea of ignorance. Under Rule 9 of the Scheme, payment and proof thereof were necessary for issuance of a discharge certificate, yet the petitioners made no contemporaneous effort to secure such certificate, nor did they raise the issue when subsequent demand notices were issued. Their prolonged silence and inaction until filing the petition indicated lack of bona fides, and the plea to deposit the amount later with interest was treated as an afterthought after the Scheme had already lapsed.

Conclusion: The petitioners were not entitled to relief under the Scheme, and the writ petition was rejected.

Ratio Decidendi: A claimant seeking benefit under a fiscal amnesty scheme must show timely payment and bona fide pursuit of the statutory process; unexplained inaction, absence of contemporaneous protest, and lack of proof of actual remittance defeat the claim for relief after the scheme has lapsed.

---