Corrigendum to declaration is not an amendment where the rule imposes no time limit on corrections, preserving exemption.

A corrigendum issued to correct an earlier declaration under Rule 173B was treated as a rectification, not as an amendment attracting the 30-day requirement in Rule 173B(2)(c). The rule required a fresh declaration or amendment within 30 days only where an actual alteration became necessary, and it did not impose any time limit on a corrigendum. As no basis was shown to treat the correction as a substantive alteration, denial of exemption on that ground was not justified. The revenue appeal therefore failed, and the assessee's exemption was sustained.

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Issues: Whether a corrigendum filed to correct a declaration under Rule 173B could be treated as an amendment attracting the 30-day requirement under Rule 173B(2)(c), so as to deny the benefit of exemption.

Analysis: The declaration had been filed within the relevant period, and the later corrigendum was only a correction or rectification of the declaration already made. Rule 173B(2)(c) required a fresh declaration or amendment within 30 days where an alteration became necessary, but it did not prescribe any time limit for a corrigendum. A corrigendum was not the same as an amendment, and there was no basis shown for treating the correction as an alteration falling within the rule.

Conclusion: The corrigendum was not hit by the 30-day requirement under Rule 173B(2)(c), and the denial of exemption was not justified.

Final Conclusion: The revenue appeal failed and the assessee's entitlement to the exemption was sustained.

Ratio Decidendi: A corrigendum that merely corrects a declaration is not an amendment or alteration for the purpose of a rule prescribing a time limit for amendments unless the rule expressly so provides.

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