Strict compliance with voluntary disclosure scheme timelines bars implied condonation when delayed payment renders the declaration non est.

A voluntary disclosure scheme requiring payment of tax with interest within a prescribed time limit was construed as mandatory, because the scheme expressly stated that noncompliance would render the declaration non est. The court held that the clear statutory timeline left no room to imply a power of condonation or to extend time on equitable grounds, and the explanation for delayed payment was rejected. The declaration therefore could not be treated as valid after belated payment, and strict compliance with the scheme's schedule was required.

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Issues: Whether the delay in payment of tax with interest under section 67 of the Voluntary Disclosure of Income Scheme, 1997 could be condoned and the declaration treated as valid despite noncompliance with the prescribed time limit.

Analysis: The Scheme fixed a clear outer limit for payment, and sub-section (2) expressly treated a declaration as non est on noncompliance with sub-section (1). The language was held to be specific and unambiguous, leaving no scope to imply a power of condonation or to extend the time schedule on equitable considerations. The explanation for the delayed payment was also found unacceptable.

Conclusion: The declaration could not be treated as valid after belated payment, and the appellant was not entitled to condonation of delay.

Ratio Decidendi: Where a voluntary disclosure scheme prescribes a clear time limit and expressly provides that noncompliance renders the declaration non est, the prescribed schedule must be strictly complied with and no condonation of delay can be implied.

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