Direct interest in attached property can make an applicant an aggrieved person entitled to amnesty scheme consideration.

A person with a direct and substantial interest in attached property may qualify as an aggrieved person for purposes of an amnesty scheme, including where the interest is asserted through a representative capacity or as a successor to the owner's interest. The petitioners were found to have a strong stake in the property attached for recovery of tax arrears: one had obtained a sale certificate in execution of her matrimonial claim, and the other was treated as acting for her mother and as a dependent with an interest in the father's estate. The rejection was set aside and the authorities were directed to reconsider the application under the applicable scheme.

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Issues: Whether the petitioners could be treated as persons aggrieved entitled to seek the benefit of the amnesty scheme in respect of the attached property.

Analysis: The petitioners had a direct and substantial stake in the property attached for recovery of tax arrears. The mother had already secured a sale certificate in execution of her matrimonial claim, and the daughter's participation in the proceedings was treated as being in a representative capacity for her mother. The daughter was also regarded as a dependent with an interest in the father's estate. In these circumstances, the petitioners' position was held to be stronger than that of a purchaser stepping into the seller's shoes, and the respondent's conduct in not availing the scheme was seen as relevant to their claim.

Conclusion: The petitioners were held to be persons aggrieved and entitled to have their application for the amnesty scheme considered.

Final Conclusion: The rejection was set aside and the authorities were directed to reconsider the petitioners' application under the applicable amnesty scheme.

Ratio Decidendi: A person with a direct and substantial interest in attached property may qualify as an aggrieved person for an amnesty scheme, including where the claim is asserted through a representative capacity or as a successor to the owner's interest.

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