Strict compliance with Sabka Vishwas payment deadline required; technical glitch could not justify relaxation of the Scheme procedure.

Under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, the prescribed payment deadline had to be strictly complied with, and a claimed technical glitch in the banking process did not justify relaxation of the mandatory procedure. The court held that attempted debit from the petitioner's bank account was insufficient where the discounted tax amount was not credited to the Revenue account by the last date. It also stated that the Scheme could not be altered through judicial intervention unless its constitutional validity was challenged. On those facts, the petitioner was denied the Scheme benefit.

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Issues: Whether the petitioner was entitled to be granted the benefit of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 despite failure to ensure credit of the discounted tax amount to the Revenue account by the prescribed last date on the plea of a technical glitch.

Analysis: The relief sought rested on the assertion that an attempted payment on the last date was debited from the petitioner's bank account but was not ultimately credited to the Revenue. The Court declined to extend the benefit of the Scheme on that basis, holding that the procedure prescribed under the Scheme had to be strictly followed and that the last date fixed for payment could not be relaxed. It distinguished the Gujarat High Court view relied upon by the petitioner and preferred the earlier view already taken by it, following the principle that the Scheme could not be altered through judicial intervention unless its constitutional validity was challenged.

Conclusion: The petitioner was not entitled to the Scheme benefit on the facts presented, and the petition was dismissed.

Ratio Decidendi: Under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, the prescribed payment deadline must be strictly complied with, and a claimed technical glitch does not justify judicial relaxation of the Scheme's mandatory procedure in the absence of a challenge to its constitutional validity.

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