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AI Drafter - (New and Powerful) ✕ Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
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Issues: Whether payment made under the Sabka Vishwas (Legacy Dispute Resolution) Scheme after the extended deadline could be accepted and the discharge certificate in Form SVLDRS-4 directed to be issued.
Analysis: The petition concerned a declaration already accepted under the Scheme, with the amount quantified and subsequently remitted after 30.06.2020. The Court noted that the delay occurred during the covid-19 period and relied on the Supreme Court's extension of limitation as well as earlier High Court decisions holding that the time-limit for remittance under the Scheme could be treated as directory rather than rigidly mandatory in the exceptional pandemic context. On that basis, the Court treated the post-deadline payment as one capable of being accepted under the Scheme and found no justification for the departmental refusal to issue the discharge certificate.
Conclusion: The post-deadline payment was directed to be accepted, and the impugned notices rejecting the petitioner's request were quashed; the petitioner was held entitled to issuance of Form SVLDRS-4.
Final Conclusion: Relief was granted to the petitioner by treating the remittance as valid under the Scheme and requiring the respondents to complete the discharge formalities.
Ratio Decidendi: Where the Scheme's payment deadline is extended or construed in light of the extraordinary covid-19 limitation orders and the statutory time prescription is treated as directory in the given context, a bona fide delayed remittance may be accepted for granting the Scheme benefit.
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