Court denies extension for tax deposit under SVLDRS-3, emphasizing scheme terms and state's benefit. Upholds scheme integrity.

The Court denied the petitioner's request for an extension to deposit discounted tax under the SVLDRS-3, citing previous judgments emphasizing strict adherence to scheme terms. The Court highlighted the importance of upholding the essence of the scheme and favored the State in cases of doubt or ambiguity regarding exemption provisions. Referring to established precedent, the Court dismissed the petition, underscoring the need to maintain the integrity of the SVLDRS scheme.

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Issues:
Petition seeking direction to deposit discounted tax under SVLDRS-3.
Contestation due to inability to avail scheme benefits before the deadline.
Interpretation of SVLDRS scheme provisions and precedent cases.
Denial of extension for depositing tax under the scheme.
Application of precedent judgments for dismissal of the petition.

Analysis:
The petitioner, an assessee, filed a petition seeking directions to deposit a discounted tax amount under the Sabka Vishwas (Legacy Dispute Resolution Scheme), 2019 (SVLDRS-3), quantified by the Designated Committee. The contention raised was the inability to avail scheme benefits due to reasons beyond control, specifically the Covid-19 pandemic.

The Court refrained from detailed adjudication as the issue was settled based on previous decisions. Citing cases like Ms. Matrics Promotion & Events and M/s Dinesh Kumar Yadav, the Court referenced the Apex Court's decision in Ms. Yashi Construction case. The Apex Court emphasized strict adherence to scheme terms and conditions, denying relief for late deposits, as it would alter the scheme's essence, a prerogative of the Government.

Highlighting the SVLDRS scheme as a comprehensive code, the Court reiterated the principle of strict construction of concession provisions in tax jurisprudence. Referring to cases like Novopan India Ltd. and B.P.L. Ltd., the Court emphasized that any doubt or ambiguity regarding exemption provisions should favor the State.

Consequently, the Court denied the extension sought by the petitioner for depositing discounted tax under the scheme, emphasizing that granting such extension would undermine the scheme's essence. Thus, the Court applied the precedent set in the case of Ms. Matrics Promotions & Events for the dismissal of the petition.

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