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In this petition, the petitioner seeks the following reliefs:

"i) Issue a writ or order or direction in the nature of Mandamus directing the Respondent No.2 to consider the letter dated 23.3.2021 (Annexure-'A') requesting to issue discharge Certificate in FORM SVLDRS-4 by considering the payment made by the Petitioner on 01.10.2020 in respect of Form SVLDRS-1 (Annexure-'E') and Form NC: 2024:KHC:35758 SVLDRS-3 (as per Annexure-'F') generated by the Respondent No.2; and

2. Heard learned counsel for the petitioner and learned counsel for the respondents and perused the material on record.

3. A perusal of the material on record will indicate that pursuant to the Show Cause Notice dated 29.10.2019 passed by the respondents, the petitioner submitted Form SVLDRS - 1 on 31.12.2019 seeking benefit of the said scheme. In pursuance of the same, the respondents issued Form SVLDRS-3 dated 01.02.2020 calling upon the petitioner to pay a sum of Rs.3,21,171.20/- for the purpose of availing the benefit of the SVLDRS. Subsequently, the attempts of the petitioner to make payment on 30.06.2020 having failed due to technical glitches in the web portal of the respondents, NC: 2024:KHC:35758 the petitioner paid the said amount to the respondents on 01.10.2020. It is the grievance of the petitioner that despite having made payment as called upon by the respondents under the SVLDRS, the respondents have issued a letter dated 12.03.2021 as a result of which, account of the petitioner at Andhra Bank, Bangalore has been frozen / blocked and since the requests by the petitioner including representation dated 23.03.2021 submitted by it to the respondents for issuance of discharge certificate in favour of the petitioner were not complied with by the respondents, petitioner is before this Court by way of the present petition.

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NC: 2024:KHC:35758 sustained and accordingly, it is liable to be set aside.

13. Thereafter, the respondent was supposed to issue Form https://www.mhc.tn.gov.in/judis SVLDRS 4 to discharge the entire liabilities towards tax under the said Scheme. However, the same has not been issued so far.

14. The learned counsel for the respondent would fairly submit that the petitioner had availed the scheme within the prescribed time and hence, they had issued Form SVLDRS 3. However, though the intimation in Form SVLDRS 3 was issued on 13.02.2020, the demanded tax amount was paid only on 25.06.2021, which is beyond the prescribed time limit. Therefore, they are not in a position to issue Form SVLDRS 4 to the petitioner to discharge the tax liabilities.

3. While so, the Union Budget presented a Scheme, viz., Sabka Vishwas Legacy Dispute Resolution Scheme, 2019 (in short, SVLDR Scheme) was introduced to settle the disputes relating to legacy laws, viz., Service ax, Central Excise Duty, etc., which
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NC: 2024:KHC:35758 are pending at various levels, by filing a declaration in Form SVLDRS-1 in the electronic portal. The petitioner opted to file a declaration under SVLDRS Scheme in https://www.mhc.tn.gov.in/judis respect of the Service Tax dispute and settle the same and accordingly filed declaration, upon which, the Designated Committee, after verifying form SVLDRS-1 filed by the petitioner, issued Form SVLDRS-3 on 13.2.2020. As per the Scheme, the petitioner is liable to pay Rs.14,98,835.20 on or before 14.03.2020. In the mean time, the Government, considering the pandemic situation, has extended the time limit for making payment under the Scheme upto 30.06.2020. However, the petitioner could not pay the tax dues on or before 30.06.2020 due to financial crisis faced by them on account of lock down owing to pandemic situation.