Sabka Vishwas scheme benefit turned on timely payment; electronic remittance within 30 days satisfied the statutory requirement.

Entitlement to Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 depended on compliance with the 30-day payment requirement under Section 127(5) of the Finance Act, 2019. The Bombay High Court treated the statement prepared on 27 May 2021 as issued only on 31 May 2021, so the petitioner's electronic payment on 30 June 2021 fell within 30 days. Earlier failed payment attempts caused by technical glitches also supported the petitioner's compliance. On these facts, denial of the scheme benefit was unwarranted and the communications refusing relief were unsustainable.

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Issues: Whether the petitioner was entitled to the benefit of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 despite the departmental view that payment had been made beyond 30 days from the date of issue of the statement under Section 127(5) of the Finance Act, 2019.

Analysis: The statement prepared on 27 May 2021 was held to have been actually issued only on 31 May 2021, and the petitioner made payment electronically on 30 June 2021, which was within 30 days from the date of issue. The record also showed unsuccessful earlier attempts to make payment due to technical glitches. On these facts, the requirement of Section 127(5) stood complied with, and denial of the scheme benefit was unwarranted.

Conclusion: The petitioner was entitled to the benefit of the scheme, and the impugned communications declining such benefit were unsustainable.

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