Background 

In this case, the assessee actor Arjun Rampal claimed a tax deduction under the Sabka Vishwas Program. The plan, which the Central government adopted on September 1 to settle ongoing litigation under the indirect tax regime, was in effect until December 31, 2019. Rampal used the program on December 30, 2019, claiming that he owed 9,16,203 Rupees in taxes. The Central Board of Indirect Taxes and Customs (CBIC) issued a form on February 23, 2020, instructing Rampal to pay 2,74,860 in order to receive the benefit under the scheme. From the CBIC portal, he received a mandate form (challan). Rampal was unable to travel to the bank to make the payment because of the widespread shutdown. The Superintendent of Investigation team, Central Goods and Services Tax, then sent Rampal reminder letters advising him that the deadline for paying tax debts had been postponed to June 30, 2020. Rampal even tried sending money via RTGS, which was reversed and returned to Rampal, in an attempt to regenerate the challan from the CBIC portal for the payment. Rampal then made failed attempts to re-generate challans and get in touch with the CGST authorities. The CGST officers notified Rampal that the date for payment has no longer been extended by the Central government on September 14, 2020. Then, Rampal was informed that his payment had been refunded because his challan had run out of validity. Rampal subsequently filed a complaint with the High Court, claiming that he was being denied the benefit of the plan despite having done nothing wrong.

Analysis of Court Order 

The Bombay High Court a division bench of Justices Nitin Jamdar and Abhay Ahuja recently granted relief to Bollywood actor and model Arjun Rampal by allowing him to avail the benefits under The now-expired Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 (SVLDR scheme) was introduced to put an end to legacy disputes in indirect tax matters that would benefit the taxpayers as well as assessees and revenue, and it recently granted relief to Bollywood actor and model Arjun Rampal by allowing him to take advantage of the benefits under it and pay his tax obligations for the financial year 2016–17. The actor-model was ordered by the court to be permitted to use the SVLDR Scheme, but Rampal was denied access for a technical reason—the sum paid had been reversed because the challan’s validity had expired.

The Bench emphasised that the taxpayers would profit from resolving old disagreements with the revenue authorities and that the authorities would free up the money that had been frozen in those disagreements. According to the Court, Rampal could not be denied the benefits of the SVLDR Scheme merely based on a technicality—the money paid before June 30, 2020, was reversed due to the challan’s expiration, which was not Rampal’s fault. As a result, the Court granted the petition and instructed the relevant parties to allow Rampal to make the requested payment of 2,74,860 Rupees under the SVLDR Scheme.