Strict construction of tax settlement schemes bars extension of time for discounted tax deposit under Sabka Vishwas.

The Madhya Pradesh HC held that extension of time to deposit the discounted tax under the Sabka Vishwas (Legacy Dispute Resolution Scheme), 2019 could not be granted because the scheme operates as a complete code and its stipulated conditions must be strictly complied with. Concessional benefits, rebates, and exemption-like provisions in tax schemes are to be construed narrowly, with any ambiguity resolved against the claimant and in favour of the Revenue. As the requested relief would have effectively altered the prescribed scheme terms, the petitioner was not entitled to relaxation of the deposit deadline.

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Issues: Whether the petitioner was entitled to extension of time to deposit the discounted tax amount under the Sabka Vishwas (Legacy Dispute Resolution Scheme), 2019.

Analysis: The relief sought required relaxation of the scheme's stipulated time limit for deposit. The scheme was treated as a complete code, and the governing principle applied was that concessions, rebates, and exemption-like benefits in tax matters must be construed strictly. The Court relied on the rule that a person seeking the benefit of such a scheme must satisfy its conditions scrupulously, and that any ambiguity in an exemption or concession provision is to operate against the claimant and in favour of the Revenue. Since extension of the prescribed period would alter the scheme itself, the requested relief could not be granted.

Conclusion: The petitioner was not entitled to extension of time for deposit under the scheme, and the challenge failed.

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