Court rules against extending SVLDRS 2019, cites petitioner's delay in payment. No post-deadline deposits allowed.

The Court dismissed the petition, ruling that it could not extend the operation of the SVLDRS, 2019 beyond the specified period or allow payment extensions. The petitioner's significant delay in payment further undermined their case. The Court found no legal basis to permit the petitioner to deposit the amount with interest post-deadline. The petition was dismissed, and all pending applications were resolved.

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Issues Involved:
1. Whether the Court can direct the Respondents to accept the payment of taxes declared by the Petitioner under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 (SVLDRS, 2019) after the expiration of the stipulated period.
2. Whether the Court can permit the Petitioner to deposit the determined amount under the SVLDRS, 2019 along with interest.
3. Whether the Court can direct the Respondents to consider the Petitioner’s representations for extension of time and payment in installments.

Detailed Analysis:

1. Acceptance of Payment Post-Deadline:
The petitioner sought a writ of Mandamus directing the Respondents to accept the payment of Rs. 68,19,084/- under the SVLDRS, 2019. The petitioner declared an amount of Rs. 1,13,65,141/- under the scheme, and the Designated Committee issued Form SVLDRS-3 on 13.03.2020, requiring payment within 30 days. The petitioner failed to make the payment within this period and the extended due date of 30.06.2020. The Court examined whether it could operationalize the SVLDRS, 2019 beyond its stipulated period. Various High Court judgments were considered, including Brahmaputra Tele Productions Pvt. Ltd. vs. Union of India, Agroha Electronics vs. Union of India, M/s Akshay Dan Charan vs. Union of India, P. Sikkandar vs. Government of India, and M/s Shekhar Resorts Limited vs. Union of India. The Court concluded that the overwhelming view is that the time for availing of the scheme cannot be extended beyond its promulgated period.

2. Permission to Deposit Amount with Interest:
The petitioner also sought permission to deposit the determined amount along with interest. The Court noted that the SVLDRS, 2019 is a time-bound amnesty scheme with no provisions for extension of time or payment in installments after the deadline. The Court referred to the judgment in M/s Akshay Dan Charan’s case, where it was held that the scheme's time limit could not be extended, and the scheme would come to an end after the stipulated period. Similarly, in P. Sikkandar’s case, the Madras High Court had initially allowed an extension but later recalled the order, emphasizing the scheme's rigid timelines. The Court thus found no basis to permit the petitioner to deposit the amount with interest beyond the scheme’s deadline.

3. Consideration of Representations for Extension and Installments:
The petitioner made multiple representations to the Respondents for an extension of time and payment in installments, which were rejected. The Court observed that the SVLDRS, 2019 did not provide for any extension of time beyond 30.06.2020. The Court referred to the judgment in Writ Tax No. 328 of 2021 by the Allahabad High Court, which stated that the scheme could not be made operational by the Court beyond its formulated period, nor could any conditions be relaxed. The Court held that it could not direct the Respondents to consider the petitioner’s representations for an extension or installments as it would contravene the scheme’s provisions.

Conclusion:
The Court dismissed the petition, holding that it could not make the SVLDRS, 2019 operational beyond its stipulated period or grant any extensions for payment. The petitioner’s delay of 1 year and 3 months from the last date of payment further weakened their case. The petition was dismissed with no merit, and all pending applications were disposed of.

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