Amnesty scheme relief cannot be denied for a minor payment mismatch where the authority itself intimated the amount payable.

A beneficial amnesty scheme for settling old tax dues must be applied to advance its purpose of expeditious dispute resolution, and a bona fide minor discrepancy in payment does not defeat relief where the assessee has paid the amount verified and intimated by the competent authority. The court treated the mismatch between the demand notice and the application as inadvertent and held that the petitioner, having withdrawn pending appeals and acted on the authority's communication, could not be denied the scheme benefit on the ground of alleged short payment.

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Issues: Whether the petitioner could be denied the benefit of the amnesty scheme for a minor shortfall in payment when the amount payable had been verified and intimated by the authority under the scheme.

Analysis: The petition arose from a dispute under an amnesty scheme framed to settle old tax recoveries by waiving interest and penalty on payment of the full principal tax. The petitioner applied under the scheme, withdrew pending appeals, and paid the amount intimated by the respondent officer after verification. The mismatch between the amount originally reflected in the demand notice and the amount mentioned in the application was held to be inadvertent, and the Court emphasised the object of the scheme as expeditious and effective resolution of old disputes rather than a technical defeat of the benefit on a trivial shortfall. The authority having itself intimated the amount payable, the petitioner acted upon that communication and paid accordingly.

Conclusion: The petitioner could not be denied the benefit of the amnesty scheme on the ground of the alleged short payment, and the impugned communication rejecting the application was unsustainable.

Ratio Decidendi: A beneficial amnesty scheme meant to resolve old dues must be applied in a manner that advances its object, and a bona fide minor discrepancy in payment does not defeat relief where the assessee has complied with the amount intimated by the competent authority.

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