Equitable relief for delayed tax payment accepted where compliance was prevented by circumstances beyond the assessee's control.

Compliance with a statutory payment deadline was treated as capable of relaxation where the assessee was prevented by circumstances beyond its control from making timely deposit under the scheme. The Court read the scheme provision as not creating an inflexible bar that would automatically invalidate the declaration for delayed payment, and applied the principle that a party should not suffer civil consequences for no fault of its own. On the facts, external restraints affected the source of funds, and the request was limited to payment of the tax amount with applicable interest within an extended period. Conditional relief was granted, and the authorities were directed to accept payment in satisfaction of the certificates if made within the stipulated time.

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Issues: Whether relief could be granted to treat the tax payment as compliant where the assessee was prevented by circumstances beyond its control from depositing the amount within the prescribed time under the scheme.

Analysis: The earlier scheme provision was understood as not creating an inflexible rule that failure to deposit within the stipulated period would automatically render the declaration non est. The Court applied the principle that a person should not suffer civil consequences or be deprived of accrued rights for no fault of their own. On the facts, the assessee was unable to arrange payment because of external restraints affecting the source of funds, and the request was limited to enabling payment with applicable interest within a further period.

Conclusion: Relief was granted in favour of the assessee by directing acceptance of the stated tax amount with interest if paid within the time allowed.

Final Conclusion: The petition was effectively allowed with conditional relief, and the tax authorities were directed to accept the payment in satisfaction of the certificates if made within the stipulated extended period.

Ratio Decidendi: Where compliance with a statutory payment deadline is prevented by circumstances beyond the party's control and the provision is not framed as an inflexible bar, equitable relief may be granted to avoid unjust civil consequences.

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