Settlement scheme benefit denied for failure to pay within the prescribed time, and the subsequent demand was upheld.

Benefit under a statutory settlement or amnesty scheme is unavailable where the declarant fails to make payment within the prescribed period and no legally sustainable basis exists to treat the delay as excusable. The designated committee had issued Form No. 3 requiring payment within 30 days under the scheme, but the petitioner did not pay within that period or by the extended date. The Court found the delay was not a mere technical lapse, noted that the original period had already expired before the Covid-19 lockdown, and held that the petitioner's conduct was inconsistent with timely compliance. The writ petition therefore failed, and the subsequent demand was not interfered with.

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Issues: Whether the petitioner was entitled to the benefit of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 despite not making payment within the prescribed period and whether the demand raised thereafter was liable to be interfered with.

Analysis: The designated committee had determined the amount payable and issued Form No. 3, requiring payment within 30 days under section 127 of the Finance Act, 2019. The petitioner's payment was not made within that period and was also not made by the extended date of 30.06.2020. The delay was not a mere technical lapse: the original period had expired before the Covid-19 lockdown, and even during the extended window no effective steps were taken to complete payment. The Court also found the conduct of the petitioner inconsistent with the claim of timely compliance.

Conclusion: The petitioner was not entitled to the scheme benefit, and the challenge to the subsequent demand failed.

Final Conclusion: The writ petition was held to be without merit because the statutory payment requirement under the settlement scheme was not complied with within the permissible time.

Ratio Decidendi: Benefit under a statutory settlement or amnesty scheme cannot be claimed when the prescribed payment period is not complied with and no legally sustainable basis exists for treating the delay as excusable.

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