A division bench of Justices Nitin Jamdar and Abhay Ahuja observed that the said scheme was brought to put an end to legacy disputes in indirect tax matters which would benefit the taxpayers as well as assessees and revenue. 

“The taxpayers would have the benefit of ending the legacy disputes with the revenue authorities and the authorities would in turn unlock the revenues that were locked up in such disputes,” the bench reasoned. 

Rampal availed of the scheme on December 30, 2019, declaring ₹9,16,203 as tax dues. 

Earlier, in 2020, a notice was issued by the Central Board of Indirect Taxes and Customs (CBIC) directing Rampal to pay the amount of ₹2,74,860 to avail of the benefit under the scheme.  However, due to the Covid lockdown, he could not visit the bank to make the payment. 

Thereafter, reminder letters were sent by the Superintendent of Investigation team, Central Goods and services tax, informing Rampal that the due date for payment of tax dues had been extended to June 30, 2020. 

Thereafter, Rampal tried to re-generate challans and contact the CGST authorities, which were unsuccessful.

Later, in September the Centre informed him that his payment had been reversed as his challan had expired. 

Rampal then approaches the High Court raising grievance that for no fault of his, he was being denied the benefit of the scheme.

The Court concluded that Rampal could not be deprived of the benefit of the SVLDR Scheme just for a technical reason that the amount paid before June 30, 2020, was reversed due to the expiry of the challan which was not Rampal’s fault.

The Court, therefore, allowed the petition and directed the authorities to permit Rampal to pay the amount of ₹2,74,860 under the SVLDR Scheme.

Advocates Bharat Raichandani and Rishab Jain briefed by UBR Legal appeared for Rampal. 

Advocates Siddharth Chandrashekar and Kush Lahankar appeared for respondent authorities.