Time-bound settlement schemes cannot be judicially extended beyond their statutory cut-off date under Sabka Vishwas

A time-bound statutory settlement scheme cannot be kept alive beyond its prescribed cut-off date in the absence of express enabling provision. Under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, payment of the amount determined by the designated committee had to be made within the scheme period and the relevant rule-based extension, and no further enlargement of time was available. The Court therefore declined to compel acceptance of the declared tax amount after expiry of the statutory deadline and rejected the request to extend the scheme by judicial direction.

---

---

Issues: Whether the Court could extend the time for payment under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 and compel acceptance of the declared tax amount after the scheme period had expired.

Analysis: The scheme was a time-bound legislative amnesty for liquidation of legacy disputes, and the amount determined by the designated committee had to be paid within the period prescribed by the scheme and the relevant rule. The petitioner did not make payment within the original period or the extended cut-off date, and the statutory framework did not provide for further enlargement of time. The Court also noted that the matter was brought belatedly, long after the last date for payment, and that the consistent view of other High Courts was that the scheme could not be kept alive or made operational by judicial direction beyond its stipulated period.

Conclusion: The request for extension of time and for enforcement of the scheme beyond its cut-off date was rejected, and the petition failed.

Ratio Decidendi: A time-bound statutory settlement scheme cannot be judicially extended beyond its prescribed period in the absence of enabling provision, and courts cannot direct its operation contrary to its express time limits.

---