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Issues: Whether the period prescribed under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 for payment of the amount determined by the Designated Committee stood extended by the Supreme Court's COVID-19 limitation orders, so as to invalidate the show-cause notice and order-in-original passed after the original payment period had expired.
Analysis: The declaration under the Scheme was accepted and the amount payable was determined under the Scheme machinery, which is quasi-judicial only up to the stage of determination. After issuance of the statement in Form SVLDR-3, the declarant was required to make payment within the period prescribed by the Scheme, as extended only by the specific notification issued under the Scheme. The Supreme Court's orders excluding limitation for judicial and quasi-judicial proceedings were held to operate for the purpose of adjudicatory timelines, not to enlarge the separate statutory time fixed for payment of an amount already determined under the Scheme. Since the amount was not paid within the extended Scheme period, the declaration lapsed, and the authorities were justified in proceeding thereafter.
Conclusion: The challenge failed. The payment period under the Scheme was not extended by the Supreme Court's limitation orders, and the writ petitioner was not entitled to quashing of the notice or the adjudication order.
Final Conclusion: The writ petition was rejected because the Scheme had to be complied with strictly, and the belated payment plea could not prevent consequential revenue after lapse of the declaration.
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