Beneficial settlement scheme relief: manual processing permitted where electronic filing failed after compliance with payment requirements.

A declarant under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 had filed the declaration and paid the quantified amount within time, but the Department could not complete electronic processing after closure of the scheme. The Tribunal held that a beneficial settlement scheme cannot be defeated by technical or technological iments where the substantive payment requirement has been met, and relied on manual processing instructions and ancillary powers to grant effective relief. It directed the Department to process the declaration manually and issue the discharge certificate within the stipulated time.

---

---

Issues: Whether the Department could be directed to manually process the declarant's application under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 and issue the discharge certificate in the absence of electronic processing.

Analysis: The declaration under the scheme had been filed, the quantified amount had been paid within time, and the only obstacle was the Department's inability to complete the process electronically after closure of the scheme. The Board's instruction on manual processing showed that valid declarations could be processed manually where electronic processing was unavailable. The scheme being a beneficial dispute-resolution measure, technical impediments could not defeat substantive rights where the declarant had already complied with the required payment obligation. The Tribunal also relied on the principle that adjudicatory bodies possess ancillary and incidental powers to do complete justice and pass consequential directions necessary to give effect to the scheme.

Conclusion: The request for manual processing of the declaration and issuance of the discharge certificate was allowed, and the Department was directed to complete the process within the stipulated time.

Final Conclusion: The appeal succeeded on the question of implementation of the settlement scheme, with directions issued to ensure completion of the statutory benefit already earned by compliance.

Ratio Decidendi: Where a declarant under a beneficial settlement scheme has complied with the payment requirement, a procedural or technological inability of the Department cannot defeat issuance of the discharge certificate, and the adjudicatory forum may direct manual processing to effectuate substantive justice.

---