False declarations under legacy dispute scheme can defeat relief even when rectification of statements is made after the prescribed period.

Under the legacy dispute resolution scheme, the Designated Committee's power to correct an erroneous SVLDRS-3 statement was treated as valid even though the rectification occurred after thirty days, because the time limit was applied as directory on the facts and the original declaration had been based on incomplete particulars. The court also held that false statements about filing manual returns and payment of tax went to the root of the declaration and disentitled the claimant to scheme relief. On that basis, the rectified statements were sustained and the writ petition was rejected.

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Issues: (i) Whether the Designated Committee could rectify the SVLDRS-3 statements beyond thirty days under the scheme; (ii) Whether false declarations regarding filing of manual returns and tax payment disentitled the petitioner to relief under the scheme.

Issue (i): Whether the Designated Committee could rectify the SVLDRS-3 statements beyond thirty days under the scheme.

Analysis: The scheme permits the Designated Committee to modify a statement within thirty days to correct an arithmetical or clerical error apparent on the face of the record. The rectified statements were issued after that period, but the Court treated the period as directory in the facts of the case and accepted the Committee's authority to correct an erroneous statement where the original declaration had been accepted on the basis of incomplete or incorrect particulars.

Conclusion: The rectification was not held invalid merely because it was made after thirty days; the challenge on limitation failed.

Issue (ii): Whether false declarations regarding filing of manual returns and tax payment disentitled the petitioner to relief under the scheme.

Analysis: The petitioner's claim that manual returns had been filed and tax had been paid was not substantiated. The Court relied on the scheme provisions that exclude persons making voluntary disclosure after filing a return showing duty payable but not paid, and on the consequence that false material particulars in a declaration can nullify the benefit. In these circumstances, the Court held that the misstatement went to the root of the declaration and vitiated the claim under the scheme.

Conclusion: The petitioner was not entitled to relief under the scheme and the rectified statements were sustained.

Final Conclusion: The writ petition was rejected because the declarations contained false material particulars and the scheme benefit could not be retained on that basis.

Ratio Decidendi: A false material declaration under a legacy dispute resolution scheme can be corrected or disregarded notwithstanding the original statement, and the statutory benefit cannot survive when the declaration itself is found to be untrue in a material respect.

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