Strict compliance with tax amnesty scheme deadlines defeats relief where payment was not made and technical glitch claims were unproven.

Strict compliance with the Sabka Vishwas (Legacy Dispute Resolution) Scheme was required for retaining its benefit, including payment within the prescribed time after issuance of SVLDRS-3. The portal record showed login activity on 29.06.2020, but no system record of any attempted payment and no login attempt on 30.06.2020, so the plea of technical glitches was rejected on the facts. Because the scheme operated as an exemption from normal tax liability, its conditions were applied strictly, and failure to pay within time could not be excused.

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Issues: Whether the appellant was entitled to retain the benefit of the Sabka Vishwas (Legacy Dispute Resolution) Scheme despite failure to pay the amount specified in SVLDRS-3 within the prescribed time on the plea of technical glitches.

Analysis: The appellant had applied for the scheme and was issued SVLDRS-3 showing the amount payable. The scheme required payment within the stipulated period, and the benefit could be obtained only on compliance with that mandate. The record of portal activity showed that the appellant logged in on 29.06.2020, but there was no system record of any attempted payment, and no login attempt was shown for 30.06.2020. In these circumstances, the explanation of technical glitches was not accepted. As the scheme operated as an exemption from the normal tax liability, its conditions had to be applied strictly.

Conclusion: The appellant was not entitled to the scheme benefit, and the failure to make payment within time could not be excused on the facts.

Final Conclusion: The appeal failed, and the denial of relief under the scheme was upheld.

Ratio Decidendi: Benefits under a tax amnesty or exemption scheme must be claimed in strict compliance with the prescribed conditions and timelines, and unsubstantiated technical difficulty will not justify relaxation of mandatory payment requirements.

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