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Issues: Whether the petitioner could claim relief under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 despite depositing the rebated service tax after the last date prescribed for payment and whether the recovery order could be interfered with.
Analysis: The petitioner's attempt to rely on earlier authority was found unhelpful because that case did not decide any question about extension of the payment deadline under the Scheme. The Court noted that the petitioner had failed to make the payment by 30.06.2020, that the amount was deposited only after that date, and that there was nothing on record to show any extension of the statutory last date. In view of the binding approach that relief under the Scheme cannot be extended beyond its terms and conditions, the delayed deposit could not confer entitlement to discharge benefits under the Scheme.
Conclusion: The petitioner was not entitled to relief under the Scheme, and interference with the recovery order was declined.