Sabka Vishwas Scheme compliance requires timely payment; later coercive recovery cannot satisfy statutory amnesty conditions.

A declarant under the Sabka Vishwas (Legacy Dispute Resolution) Scheme must comply with the payment requirement within the prescribed timeline, including any valid extensions. Here, the declaration was filed and Form-3 issued, but the balance amount was not remitted within time. Later credits made through departmental recovery proceedings under Section 87 of the Finance Act, 1994 were coercive recoveries, not voluntary Scheme payments, and therefore did not satisfy the Scheme conditions. The Court held that full compliance with the Scheme was mandatory, rejected reliance on an inapplicable COVID-related precedent, and upheld the attachment and recovery action. The writ petition failed.

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Issues: Whether the petitioner was entitled to avail the Sabka Vishwas (Legacy Dispute Resolution) Scheme benefits after paying the balance amount beyond the stipulated time, and whether the attachment and recovery measures taken by the Department were liable to be set aside.

Analysis: The declaration under the Scheme was filed and a Form-3 statement was issued, but the amount payable under the statement had to be remitted within the time prescribed under the Scheme and the extensions granted by the relevant notifications. The petitioner did not make payment within that period. The amounts later credited were recovered by the Department in recovery proceedings under Section 87 of the Finance Act, 1994 and were not voluntary payments made by the petitioner within the Scheme timeline. The Scheme required compliance with its conditions in toto, and the later recovery could not be treated as satisfaction of the Scheme requirement. The reliance placed on the decision concerning COVID-related legal impediment was found inapplicable because the inability there arose from a statutory bar, which was absent here.

Conclusion: The petitioner was not entitled to the Scheme benefit on the basis of belated payment, and the recovery and attachment action was upheld.

Final Conclusion: The writ petition failed because the Scheme conditions were not complied with within the prescribed time, and subsequent departmental recovery did not revive the petitioner's entitlement to the statutory amnesty.

Ratio Decidendi: A declarant under the Sabka Vishwas Scheme must satisfy the payment requirement within the prescribed period, and amounts recovered later in coercive recovery proceedings cannot be treated as payment made under the Scheme.

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