Discharge certificate under Sabka Vishwas Scheme cannot be denied on manual-processing objections after payment is made.

A Madras HC decision on the Sabka Vishwas Legacy Dispute Resolution Scheme held that a discharge certificate could not be refused on the purely administrative ground that manual processing was unavailable, where the assessed amount had already been paid and the Designated Committee had treated the liability as nil. The court treated the refusal as inconsistent with the statutory scheme and set it aside. It also held that the connected show cause notice could not survive once the scheme payment was complete and discharge relief was otherwise due, and quashed that notice as well. The ratio emphasises that scheme benefits must be given effect and cannot be defeated by internal processing difficulties.

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Issues: (i) Whether the rejection of the request for issuance of a discharge certificate under the Sabka Vishwas Legacy Dispute Resolution Scheme on the ground that manual processing was not permissible was sustainable. (ii) Whether the show cause notice could survive once the amount determined under the Scheme had been paid and the request for discharge certificate was otherwise entitled to be processed.

Issue (i): Whether the rejection of the request for issuance of a discharge certificate under the Sabka Vishwas Legacy Dispute Resolution Scheme on the ground that manual processing was not permissible was sustainable.

Analysis: The amount determined under the Scheme had already been paid and the Designated Committee had treated the liability as NIL. The only remaining step was issuance of the discharge certificate. The reason cited in the rejection order, namely that there was no provision for manual processing and that a court order was required, was treated as an internal administrative difficulty that could not defeat the statutory scheme or the petitioner's entitlement.

Conclusion: The rejection order was unsustainable and was set aside in favour of the assessee.

Issue (ii): Whether the show cause notice could survive once the amount determined under the Scheme had been paid and the request for discharge certificate was otherwise entitled to be processed.

Analysis: The notice was linked to the same completed Scheme proceedings and to the denial of discharge certificate. Once the refusal to issue the discharge certificate was found untenable, the notice no longer had an independent basis to continue.

Conclusion: The show cause notice was also set aside in favour of the assessee.

Final Conclusion: The petitioner was held entitled to have the Scheme request manually processed and to receive the discharge certificate, with the consequential quashing of the pending show cause notice.

Ratio Decidendi: A completed tax-settlement scheme benefit cannot be denied on a purely administrative ground of non-manual processing where the liability has already been determined and paid; the authority must give effect to the scheme and grant consequential discharge relief.

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