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    <title>2023 (5) TMI 13 - BOMBAY HIGH COURT</title>
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    <description>Denial of relief under the SVLDR Scheme on the ground that payment could not be credited due to expiry of the mandate/challan was held unsustainable where the assessee had initiated payment by RTGS within the prescribed period, but the amount was later reversed and refunded solely because of an expired challan, without any fault attributable to the assessee. Applying the SC&#039;s approach that a declarant cannot be penalised for failure caused by technical/system constraints beyond its control, the HC held that technical reversal could not defeat the scheme&#039;s remedial object of resolving legacy disputes. The authorities were directed to accept the quantified amount pursuant to the SVLDRS-3 and, upon payment, issue the discharge certificate; the writ petition was allowed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=437206</link>
      <description>Denial of relief under the SVLDR Scheme on the ground that payment could not be credited due to expiry of the mandate/challan was held unsustainable where the assessee had initiated payment by RTGS within the prescribed period, but the amount was later reversed and refunded solely because of an expired challan, without any fault attributable to the assessee. Applying the SC&#039;s approach that a declarant cannot be penalised for failure caused by technical/system constraints beyond its control, the HC held that technical reversal could not defeat the scheme&#039;s remedial object of resolving legacy disputes. The authorities were directed to accept the quantified amount pursuant to the SVLDRS-3 and, upon payment, issue the discharge certificate; the writ petition was allowed.</description>
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