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    <title>2024 (7) TMI 464 - GUJARAT HIGH COURT</title>
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    <description>A beneficial amnesty scheme was construed to extend remission of interest and penalty where the assessee had already discharged the tax component before assessment and the dispute concerned a composite liability of tax, interest and penalty. The demand in the intimation letter could not be treated as a separate bar to relief when, on a conjoint reading of the scheme clauses, it represented only the penal component after tax had been paid. A hyper-technical reading inconsistent with the scheme&#039;s object of resolving old disputes was rejected, and the rejection of the application and consequential recovery were held unsustainable; the benefit was to be granted and the recovered amount refunded with statutory interest.</description>
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      <description>A beneficial amnesty scheme was construed to extend remission of interest and penalty where the assessee had already discharged the tax component before assessment and the dispute concerned a composite liability of tax, interest and penalty. The demand in the intimation letter could not be treated as a separate bar to relief when, on a conjoint reading of the scheme clauses, it represented only the penal component after tax had been paid. A hyper-technical reading inconsistent with the scheme&#039;s object of resolving old disputes was rejected, and the rejection of the application and consequential recovery were held unsustainable; the benefit was to be granted and the recovered amount refunded with statutory interest.</description>
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