Timely payment under Sabka Vishwas Scheme includes bank debit before deadline, despite later government credit.

Debiting the petitioners' bank account on 30 June 2020 was treated as timely payment under Rule 7 of the Sabka Vishwas (Legacy Dispute Resolution) Scheme Rules, 2019, even though the amount reached the Government account on 1 July 2020. The Court viewed the Scheme as a beneficial amnesty measure, noted that the Designated Committee had already determined the tax dues, and held that the petitioners were not responsible for the inter-bank or portal-related delay. The short lag between debit and credit could not defeat compliance where payment was initiated within the extended deadline. The petitioners were therefore entitled to the discharge certificate, and rejection of their declaration was unsustainable.

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Issues: Whether the amount debited from the petitioners' bank account on 30 June 2020, but credited to the Government account on 1 July 2020, constituted timely payment under Rule 7 of the Sabka Vishwas (Legacy Dispute Resolution) Scheme Rules, 2019, so as to entitle the petitioners to a discharge certificate under the Scheme.

Analysis: The Scheme was a beneficial amnesty measure intended to conclude legacy tax disputes. The Designated Committee had already determined the tax dues under the Scheme, thereby recognising the petitioners' eligibility. The record showed that the petitioners' bank account was debited on 30 June 2020 and the payment upload status showed processing on that date. The Court treated debit from the payer's bank account as payment for the purposes of compliance with Rule 7, and held that the petitioners were not at fault for the inter-bank and portal-related delay in crediting the amount to the Government account on the next day. The short time lag between debit and credit could not defeat the benefit of the Scheme where the petitioners had acted within the extended deadline and the delay was not attributable to them.

Conclusion: The delayed credit on 1 July 2020 did not render the payment belated. The petitioners were entitled to the discharge certificate, and the rejection of their declaration was unsustainable.

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