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Issues: Whether the petitioner was entitled to the benefit of the Sabka Vishwas (Legacy Disputes Resolution) Scheme, 2019 despite the amount due under Form SVLDRS-3 not getting finally credited within the extended time on account of repeated banking and server-related technical failures.
Analysis: The petitioner had opted into the scheme, its declaration was accepted, and Form SVLDRS-3 quantified the amount payable. The record showed that the petitioner had sufficient balance and made repeated attempts to remit the amount within time, but the debit entries were reversed and the transfer could not be completed because of technical problems beyond the petitioner's control. In such circumstances, the denial of scheme benefits solely on the ground of non-credit of the amount before the cut-off date was held to be unjustified, particularly when the delay was not attributable to any lack of diligence on the part of the petitioner.
Conclusion: The petitioner was held entitled to settlement under the scheme, and the rejection of the petitioner's claim for want of timely payment was set aside. The petitioner was directed to pay interest at 13% per annum on the quantified amount within the time stipulated in the order, after which the matter would stand settled under the scheme.
Final Conclusion: Technical failure in effectuating payment within the extended period did not defeat the petitioner's entitlement to the statutory settlement scheme where timely attempts were made and sufficient funds were available.
Ratio Decidendi: A beneficial dispute-resolution scheme cannot be denied for non-credit of the payable amount within time when the assessee made timely bona fide attempts to pay and the failure resulted from technical glitches beyond the assessee's control.
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