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Issues: Whether the declarant was eligible to seek relief under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 on the basis of a voluntary disclosure; whether the amount quantified in SVLDRS-3 was paid within the prescribed time; and whether an incorrect declaration and belated payment disentitled the declarant from the scheme benefit.
Analysis: The declaration was made in the voluntary disclosure category. Under the scheme, a person making a voluntary disclosure is not entitled to any relief on tax dues, and the Designated Committee is not required to verify the correctness of such disclosure at that stage. The scheme also requires payment of the amount stated in SVLDRS-3 within 30 days. The declaration was filed in time, but the amount was not paid within the prescribed period. The subsequent payment was beyond time and did not cure the default. The later adjudication also showed that the disclosures made in the declaration were not true, reinforcing that the declarant was not entitled to the benefit of the scheme.
Conclusion: The declarant was not entitled to the benefit of the scheme, and the challenge to the rejection of the claim failed.
Final Conclusion: The writ petition was unsustainable because the claim under the settlement scheme was both untimely in payment and unsupported by a correct declaration, leaving the tax demand and consequential proceedings intact.
Ratio Decidendi: A person invoking the voluntary disclosure category under the Sabka Vishwas scheme must make a correct declaration and comply with the prescribed payment timeline, failing which the scheme benefit cannot be claimed.
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