Bona fide compliance with a tax settlement scheme cannot be denied because of electronic payment failures during the Covid-19 period.

Bona fide efforts to pay under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 could not be defeated by electronic payment failures during the Covid-19 period. The petitioner had already been accepted under the Scheme, Form SVLDRS-3 had been issued, and payment was attempted through RTGS within time, but the bank returned the amount and the portal did not generate a challan. The Court held that the Scheme's beneficial object required substantive compliance to prevail over procedural or technological impediments, and used writ jurisdiction to ensure implementation. The authorities were directed to accept the payment with interest and grant discharge under the Scheme.

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Issues: Whether the petitioner, having made bona fide attempts to pay the amount determined under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 but being prevented by technical difficulties in the electronic payment process during the Covid-19 period, was entitled to make payment manually and obtain the benefit of the Scheme.

Analysis: The declaration filed by the petitioner was accepted and Form SVLDRS-3 was issued determining the amount payable. The record showed that the petitioner attempted payment through RTGS within time, but the amount was returned by the receiving bank, and the challan could not be generated successfully on the portal. The Court held that the petitioner's efforts were bona fide and were made to comply with the Scheme in extreme pandemic conditions. As the object of the Scheme is to reduce legacy litigation and permit settlement of dues, the substantive benefit could not be denied merely on procedural or technical grounds. The Court therefore exercised writ jurisdiction to ensure implementation of the Scheme in the facts of the case.

Conclusion: The petitioner was entitled to the benefit of the Scheme, and the authorities were directed to accept the payment with interest and grant the discharge under the Scheme.

Ratio Decidendi: A bona fide attempt to comply with a beneficial tax settlement scheme cannot be defeated by procedural or technological obstacles where the assessee has otherwise been found eligible and the amount payable has been determined.

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