Beneficial settlement scheme permits rectification of minor declaration errors and requires consideration on merits despite filing deadline.

Under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, a declaration could not be rejected for a minor clerical error where the correct order particulars were already available with the department. The HC read the scheme as a beneficial settlement framework and held that the designated committee's role continues after filing through scrutiny and rectification. It further held that the filing cut-off date is only a deadline for submission and does not make the committee functus officio for pending declarations. The mistaken reference to the appeal order instead of the order-in-original was treated as a trivial defect, and the declaration was directed to be considered on merits after rectification.

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Issues: Whether a declaration under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 could be rejected for mentioning the order-in-appeal number and date instead of the order-in-original particulars, and whether the designated committee remained empowered to process and rectify the declaration after the last date for filing.

Analysis: The scheme was construed as a settlement-oriented beneficial measure, and the relevant provisions were read together to hold that the designated committee's role begins after a declaration is filed and continues through scrutiny, statement issuance, and rectification. Section 127 was treated as enabling correction of clerical or arithmetical errors apparent on the face of the record, and the cut-off date for filing was held to be only a deadline for submission, not a limit that made the committee functus officio for pending declarations. Since the department already had the correct materials and the mistake was only in entering the wrong appeal-related particulars, the defect was regarded as trivial and technical rather than substantive.

Conclusion: The rejection of the declaration was unjustified, and the assessee was entitled to have the error rectified and the application considered on merits.

Final Conclusion: The challenge to the rejection failed, the assessee obtained the benefit of reconsideration under the scheme, and the connected proceedings were disposed of accordingly.

Ratio Decidendi: Under a beneficial settlement scheme, a declaration cannot be rejected for a minor clerical mistake where the correct particulars are already within the department's knowledge, and the statutory power to rectify such errors survives the filing cut-off for the purpose of processing pending declarations.

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