Facts of the Case
The petitioners filed declarations under the Direct
Tax Vivad Se Vishwas Act, 2020 through Forms 1 and 2 on 26 March 2021. However,
while filing, the amounts paid through challans were inadvertently declared
excluding the interest component.
Subsequently, the respondents issued Forms 3 on 22
April 2021 but denied credit for the taxes already deposited, citing “mismatch”
issues. In certain cases, no reasons were provided for such denial.
The petitioners submitted representations seeking
rectification of Forms 3 and requested that credit for taxes already paid be
allowed. Attempts to file Forms 4 were unsuccessful due to a system-generated
error indicating that the “date of deposit cannot be before the filing date of
Forms 1 and 2.”
Later, the respondents rejected the representations by communication dated 7 April 2022 on the ground that tax had been deposited under minor head “200” instead of “400.”
Issues
Involved
- Whether credit of taxes deposited can be denied under the DTVSV Act
due to technical errors such as incorrect minor head classification.
- Whether procedural or software-related limitations can override
substantive rights of taxpayers.
- Whether the rejection of credit on technical grounds defeats the object of the DTVSV Scheme.
Petitioner’s
Arguments
- The petitioners contended that taxes had been duly deposited and
the denial of credit was purely on technical grounds.
- It was argued that incorrect selection of minor head (200 instead
of 400) was a bona fide mistake.
- The respondents had already accepted Forms 1 and 2, and therefore
denial of credit later was arbitrary.
- The system error preventing filing of Forms 4 was unjust and beyond
the control of the petitioners.
- The object of the DTVSV Act is to resolve disputes, not to reject claims on hyper-technical grounds.
Respondent’s
Arguments
- The respondents submitted that the Assessing Officer was attempting
to correct the challan code but faced technical limitations due to
software restrictions.
- It was argued that if the system does not permit correction, granting relief would be difficult.
Court’s
Findings / Order
- The Court observed that there was no dispute that the
petitioners had deposited the taxes.
- Denial of credit merely because of incorrect minor head
classification was held to be unfair, illegal, and contrary to the
objective of the DTVSV Act.
- The Court emphasized that technicalities cannot defeat
substantive rights.
- It held that software limitations cannot be used as a ground to
deny legitimate relief.
- The Court directed the respondents to:
- Correct the payment heads
- Grant credit for taxes deposited
- Issue revised Forms 3 within four weeks
- Allow petitioners to file Forms 4 thereafter
Important
Clarification by Court
The Court made a significant observation:
Technology is intended to facilitate transactions
and cannot be used to defeat legal rights.
It further clarified that software must be
adapted to legal requirements, not vice versa, reinforcing taxpayer
protection against procedural rigidity.
Link to download the order -https://delhihighcourt.nic.in/app/case_number_pdf/2022:DHC:2743-DB/MMH19072022CW85902022_175937.pdf
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