Statutory immunity depends on strict compliance with payment procedure, and retrospective interest applies until actual payment.

Statutory immunity under the Voluntary Disclosure of Income and Wealth Act was conditioned on strict compliance with section 5 payment requirements. Where the declarant neither paid wealth-tax before filing the declaration nor obtained permission for deferred payment or instalments, later payment in two instalments did not satisfy the prescribed procedure. The amended section 15(5A) applied retrospectively and required simple interest on the unpaid amount from 1 April 1976 until actual payment as a condition for immunity under section 15(1). The demand for interest was therefore valid, and compliance with the statutory payment mechanism was mandatory.

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Issues: Whether interest was payable under section 15(5A) of the Voluntary Disclosure of Income and Wealth Act, 1976, as amended, where the declarant had not complied with the payment requirements under section 5 in the manner contemplated by the Act.

Analysis: Section 15(5A) made entitlement to immunity under section 15(1) dependent upon compliance with section 5. The declarant had not paid the wealth-tax before making the declaration and had also not obtained permission for deferred payment or instalments under section 5(2). Mere payment of the tax in two instalments, without following the statutory procedure, was not payment in accordance with section 5. The amended provision applied retrospectively and required payment of simple interest on the amount remaining unpaid from 1 April 1976 until the date of actual payment as a condition for immunity.

Conclusion: The demand for interest was valid and the petitioner was liable to pay interest to obtain immunity under section 15(1).

Ratio Decidendi: Where statutory immunity is made conditional upon payment in accordance with prescribed procedure, compliance with the procedural requirement is mandatory and retrospective amendment imposing interest as a condition for immunity is enforceable.

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