TMI Blog2000 (2) TMI 82X X X X Extracts X X X X X X X X Extracts X X X X ..... sclosure of Income Scheme introduced by the Finance Act of 1997, on December 30, 1997, under section 67 of the Act. The petitioner ought to have paid the tax at the latest on March 30, 1998, with interest at the rate of two per cent. for every month or part thereof calculated from the date of filing the declaration. Sub-section (1) of section 67 requires that the proof of payment of tax shall be f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... "I am directed to refer to your representation dated September 22, 1999, regarding condonation of delay under the Voluntary Disclosure of Income Scheme and to say that the Voluntary Disclosure of Income Scheme certificates can be issued only in those cases where the tax has been paid on/within the period of 90 days. The Board have considered your petition and is of the view that the judgment in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... incing explanation for non-payment of tax within the period of three months allowed by the scheme, the petitioner cannot be said to have made out any case for extending the statutorily prescribed time limit or for showing any indulgence. Unless there is specific provision for condonation of delay, the question of granting any relief under article 226 does not arise, more so, when the petitioner ha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... are unable to agree with that observation which goes plainly contrary to the relevant provisions of the statute, viz., section 67(1) and (2). The further observation that the provisions of taxing statute are to be construed liberally does not accord with the accepted principles of interpretation of a taxing statute. We respectfully differ with the aforesaid observations made by the Division Bench ..... X X X X Extracts X X X X X X X X Extracts X X X X
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