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HC allowed the petitioner's challenge to tax demand notices under SVLDRS-3, finding the time limit provisions directive rather than mandatory. The court held that COVID-19 pandemic circumstances justified extending the scheme's deadline. Rejecting the respondents' rigid interpretation, the HC directed recalculation of tax liability, acceptance of delayed payment, and issuance of discharge certificate. The decision aligns with the scheme's objective of facilitating tax dispute resolution and providing relief during extraordinary circumstances. The court emphasized the scheme's intent to enable taxpayers to settle past central excise and service tax liabilities, particularly in light of the pandemic's economic challenges.
HC allowed the petitioner's challenge to tax demand notices under SVLDRS-3, finding the time limit provisions directive rather than mandatory. The court held that COVID-19 pandemic circumstances justified extending the scheme's deadline. Rejecting the respondents' rigid interpretation, the HC directed recalculation of tax liability, acceptance of delayed payment, and issuance of discharge certificate. The decision aligns with the scheme's objective of facilitating tax dispute resolution and providing relief during extraordinary circumstances. The court emphasized the scheme's intent to enable taxpayers to settle past central excise and service tax liabilities, particularly in light of the pandemic's economic challenges.
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