Sabka Vishwas scheme benefit preserved despite failed payment transfer, subject to payment of the quantified amount with interest.

Failure to complete payment under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 because of failed NEFT/RTGS transfers and technical debit-credit reversal was treated as a technical impediment, not deliberate default. The Court held that the scheme's amnesty benefit should not be denied on these facts, but the benefit was made conditional on payment of the quantified amount together with interest at 9% from 30.06.2020 within the time fixed. On such compliance, the adverse order confirming the service tax demand was liable to be quashed.

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Issues: Whether the petitioner was entitled to retain the benefit of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 despite delay in payment of the amount quantified in Form SVLDRS-3, and whether the adverse order confirming the service tax demand was liable to be quashed subject to payment with interest.

Analysis: The petitioner had opted for settlement under the Sabka Vishwas (Legacy Dispute Resolution) Scheme Rules, 2019 and had received Form SVLDRS-3 quantifying the amount payable. The attempt to pay on 30.06.2020 through NEFT and then RTGS failed, and the amount was debited and re-credited, indicating a payment failure attributable to technical difficulties rather than deliberate default. The scheme was treated as conferring a substantial amnesty benefit, and the Court held that such benefit should not be denied on these facts, but only upon compliance with the quantified amount together with interest at 9% from 30.06.2020 within the time stipulated in the order.

Conclusion: The petitioner was held entitled to the scheme benefit subject to payment of the quantified amount with interest, and the impugned order was liable to be quashed upon such compliance.

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