Court upholds denial of relief under SVLDRS Scheme for late tax deposit, emphasizing adherence to terms.

The Court dismissed the petition seeking relief under the SVLDRS Scheme due to late deposit of tax amount post the extended deadline, emphasizing adherence to Scheme's terms and conditions. Referring to judicial precedents, including an Allahabad High Court decision affirmed by the Apex Court, the Court upheld the government's prerogative in maintaining the Scheme's integrity. Granting relief post deadline would amount to modifying the Scheme, which was deemed impermissible. The decision underscored the significance of complying with Scheme provisions and specified deadlines, leading to the denial of benefits to the petitioner.

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Issues:
Petition under Article 226 for relief under SVLDRS Scheme - Late deposit of tax amount - Extension of last date due to Covid lockdown - Denial of benefit under the Scheme - Judicial precedent from Allahabad High Court and Apex Court.

Analysis:
The petitioner, an assessee registered under the CGST Act, filed a petition under Article 226 seeking relief under the SVLDRS Sabka Vishwas (Legacy Dispute Resolution) Scheme. The petitioner had applied to avail the benefits of the Scheme by offering a tax payable amounting to Rs.3,51,611.60. The Designated Committee under the Scheme issued a statement for depositing the said amount within 30 days. However, due to the Covid-19 lockdown, the Government extended the last date for depositing the amount to 30th June, 2020. The petitioner failed to deposit the amount by the extended deadline and made the deposit on 14.02.2022 instead.

The petitioner approached the Court seeking direction to accept the tax amount deposited after the extended deadline to avail the Scheme benefits. The respondents referred to a Division Bench order of the Allahabad High Court in a similar case where relief was denied for late deposit. The Apex Court confirmed the Allahabad High Court's decision, emphasizing the need to adhere to the terms and conditions of the Scheme strictly. Granting relief post the specified deadline would amount to modifying the Scheme, which falls under the government's prerogative.

Considering the precedents and the terms of the SVLDRS Scheme, the Court dismissed the petition, stating that accepting the late deposit would undermine the Scheme's integrity. The petitioner's application had to be evaluated within the Scheme's framework, and the delayed deposit of the discounted tax amount could not be accepted. Therefore, the Revenue was justified in denying the petitioner the benefit under the Scheme.

In conclusion, the Court's decision was based on upholding the integrity of the SVLDRS Scheme and ensuring compliance with its terms and conditions. The judgment highlighted the importance of adhering to the specified deadlines and not altering the Scheme's provisions arbitrarily.

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