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    <title>2025 (6) TMI 1737 - GUJARAT HIGH COURT</title>
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    <description>A beneficial dispute-resolution scheme could not be denied on curable identity defects where the penalty had been imposed on the applicant in his individual capacity and no statutory ineligibility was shown under Section 125 of the Finance (No. 2) Act, 2019. The mismatch in surname and PAN was a technical error capable of correction, especially where the authorities had accepted a connected declaration without objection. A prior judicial direction was not required to compel merits-based consideration of the representation. The declaration was therefore to be processed with correction of the name and PAN, and the next form under the scheme was to be issued.</description>
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      <description>A beneficial dispute-resolution scheme could not be denied on curable identity defects where the penalty had been imposed on the applicant in his individual capacity and no statutory ineligibility was shown under Section 125 of the Finance (No. 2) Act, 2019. The mismatch in surname and PAN was a technical error capable of correction, especially where the authorities had accepted a connected declaration without objection. A prior judicial direction was not required to compel merits-based consideration of the representation. The declaration was therefore to be processed with correction of the name and PAN, and the next form under the scheme was to be issued.</description>
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