Cut-off date under an amnesty scheme bars late declarations from claiming interest waiver or parity relief.

A beneficial settlement scheme with a clear cut-off date could not be extended to a declarant who filed after the prescribed deadline. The Court held that waiver of interest was unavailable because the petitioner's declaration was admittedly late and therefore outside the scheme. Parity with another assessee also failed, since that case had complied with the scheme conditions and was not a valid basis for identical relief. The Court further noted the petitioner's prior unsuccessful proceedings and non-compliance with directions on interest payment, making Article 226 relief inappropriate on the facts.

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Issues: Whether the petitioner was entitled to waiver of interest under the Trade Notice and Amnesty Scheme despite having submitted the declaration after the prescribed cut-off date, and whether parity could be claimed with another assessee whose application had been entertained.

Analysis: The claim for waiver was rejected because the scheme expressly required declarations to be filed on or before the cut-off date of 31-12-1986. The petitioner's declaration was admittedly filed later, and the case was therefore outside the scheme. The earlier relief granted to another assessee did not assist the petitioner, because that application had been made within time. The Court also noted that the petitioner had already failed before the Bombay High Court and had not complied with directions relating to payment of interest, making the writ petition an inappropriate invocation of Article 226 jurisdiction.

Conclusion: The petitioner was not entitled to waiver of interest or similar relief, and the challenge failed.

Ratio Decidendi: Where a beneficial settlement scheme prescribes a clear cut-off date, relief cannot be claimed by an applicant who files the required declaration after that date, and parity cannot be invoked on the basis of a case that satisfied the scheme conditions.

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