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Petitioner ineligible for SVLDRS 2019 benefits due to non-payment within stipulated period; subsequent recoveries treated as arrears under Finance Act.

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....The HC held that since the petitioner failed to pay the determined amount under SVLDRS Form-3 within the stipulated period, the petitioner could not avail the benefit offered under the SVLDRS, 2019 scheme. The amounts recovered by the Department were not payments made within the scheme's period but subsequent recoveries of arrears u/s 87 of the Finance Act, 1994. As the petitioner became the firm's Managing Partner after the reconstituted partnership deed, the HC found no merit in challenging the attachment order and dismissed the petition.....