Strict construction of Amnesty Scheme bars relief where Modvat credit reversal and interest payment occurred after the cut-off date.

Amnesty Scheme benefits were not available where reversal of Modvat credit and payment of differential interest were made only after the scheme's cut-off date. The scheme had to be construed strictly, and no discretion could be used to extend relief beyond its clear terms. Earlier authority allowing partial reversal around the cut-off date was distinguished because, on the facts here, both the differential Modvat credit and differential interest were reversed only on 31-3-1998, after the relevant deadline. The benefit of the Amnesty Scheme was therefore held inadmissible.

---

---

Issues: Whether the benefit of the Amnesty Scheme was admissible when the reversal of Modvat credit and payment of differential interest were made after the scheme's cut-off date.

Analysis: The scheme was required to be construed strictly, and no discretion could be exercised beyond its clear language. The reliance on an earlier decision permitting partial reversal around the cut-off date was distinguished because, in the present matter, both the differential Modvat credit and the differential interest were reversed only on 31-3-1998, well after the cut-off date. In taxing matters, there is no room for intendment, and the benefit of the scheme could not be extended contrary to its terms.

Conclusion: The benefit of the Amnesty Scheme was held to be inadmissible to the respondent.

---