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Issues: Whether the petitioner was entitled to the benefit of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 and issuance of Form SVLDRS-4 despite delayed payment caused by banking technical glitches, and whether the amount subsequently recovered under the GST recovery proceedings was liable to be refunded.
Analysis: The petitioner had been issued Form SVLDRS-3 determining the amount payable under the scheme. It made payment within the stipulated period, but the amount did not get credited because of technical failure and was re-credited. The payment was attempted again, yet the due period had expired by then. The scheme was meant to resolve legacy disputes and reduce litigation, and a bona fide attempt to comply with the scheme conditions could not be defeated by procedural or technical failure beyond the petitioner's control. The Court relied on the principle that an assessee who has substantially complied and was prevented by circumstances beyond control should not be denied the scheme benefit, especially in the backdrop of the Covid-19 period.
Conclusion: The petitioner was entitled to the scheme benefit. The designated committee was directed to appropriate the payment already made towards the settlement dues, issue the discharge certificate, and refund the amount recovered under the coercive recovery proceedings with interest.
Ratio Decidendi: A bona fide attempt to comply with the payment requirement under a settlement scheme cannot be defeated by technical failure beyond the declarant's control, and the substantive benefit of the scheme may be enforced in writ jurisdiction to prevent denial of relief on mere procedural default.
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