Strict compliance with statutory settlement timelines bars belated adjustment claims under the Sabka Vishwas scheme.

A declarant under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 must strictly comply with the prescribed payment timeline and conditions. The petitioner sought a fresh SVLDRS-3 by treating earlier payments as pre-deposit after the scheme period had expired, but the Court held that such belated adjustment could not be allowed. It further held that COVID-related limitation relief could not be extended to alter the scheme's payment deadline. The requested relief was therefore rejected because a statutory settlement scheme cannot be rewritten to accommodate a late claim.

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Issues: Whether the petitioner, having failed to make payment within the time prescribed under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, could seek issuance of fresh SVLDRS-3 by treating earlier payments as pre-deposit and obtain consequential relief.

Analysis: The declarations were filed as arrears-based service tax liabilities under the scheme, and the amount indicated in the statement under the scheme was required to be paid by the prescribed outer date. The petitioner's first assertion seeking adjustment of the alleged pre-deposit was made only after the expiry of the scheme period. The Court held that extending the benefit of limitation orders passed in COVID-related proceedings to the payment deadline under the scheme was not permissible. Granting the requested relief would amount to altering the scheme's terms, which is impermissible in a statutory settlement framework.

Conclusion: The petitioner was not entitled to a fresh SVLDRS-3 by belatedly claiming adjustment of the alleged pre-deposit, and the claim was rejected.

Final Conclusion: Relief under the settlement scheme could not be granted contrary to its prescribed timeline and conditions, and the petition failed on that ground.

Ratio Decidendi: A declarant seeking the benefit of a statutory settlement scheme must strictly comply with its time limits and conditions, and the Court cannot extend or rewrite the scheme to accommodate a belated claim for adjustment of payment.

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