Statutory payment deadlines under a voluntary disclosure scheme cannot be extended on vague explanations for delay.

A statutory time limit under the Voluntary Disclosure of Income Scheme, 1997 could not be enlarged by judicial interpretation, so refusal to condone a 16-day delay in payment of tax was upheld. The explanation that resources could not be mobilised was too vague and insubstantial to justify relief, and the delay was not shown to have arisen from circumstances beyond the taxpayer's control. As a result, the declaration was validly treated as non est and the challenge failed.

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Issues: Whether refusal to condone the 16-day delay in payment of tax under section 67(1) of the Voluntary Disclosure of Income Scheme, 1997, and the resulting treatment of the declaration as non est, was illegal.

Analysis: The scheme prescribed a strict time limit for payment of tax, and the Court found no basis to read into it a power to relax or enlarge that limit by interpretation. The explanation offered for the delay was only that resources could not be mobilised, which was held to be too vague and insubstantial to justify relief. The Court also found that the delay was not shown to have occurred for reasons beyond the petitioner's control.

Conclusion: The refusal to condone delay was upheld and the challenge to the declaration being treated as non est failed.

Ratio Decidendi: A statutory time limit under a voluntary disclosure scheme cannot be enlarged by judicial interpretation, and delay will not be excused on a vague or inadequate explanation that does not show circumstances beyond the taxpayer's control.

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