Voluntary disclosure compliance may require interest payment to secure immunity where prescribed payment procedure was not followed. Where full tax was paid on or before the cutoff but not in conformity with section 5(2) - for example, no application to the Commissioner for time or no extension due to inadequate security - a strict view treats such payments as not in accordance with the Act; accordingly sections 14(5A)/15(5A) require that the interest specified therein also be paid before the prescribed deadline for the declarant to qualify for the immunity in sections 14(1) and 15(1).
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Provisions expressly mentioned in the judgment/order text.
Voluntary disclosure compliance may require interest payment to secure immunity where prescribed payment procedure was not followed.
Where full tax was paid on or before the cutoff but not in conformity with section 5(2) - for example, no application to the Commissioner for time or no extension due to inadequate security - a strict view treats such payments as not in accordance with the Act; accordingly sections 14(5A)/15(5A) require that the interest specified therein also be paid before the prescribed deadline for the declarant to qualify for the immunity in sections 14(1) and 15(1).
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