2001 (6) TMI 36

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..... J.--We see no legal infirmity in the order passed by the learned single judge (see [2001] 247 ITR 356) holding that in view of noncompliance of section 67(1) of the Voluntary Disclosure of Income Scheme, 1997, the declaration filed by the writ petitioner shall be deemed to be non est under the Scheme by virtue of the explicit declaration contained in sub-section (2) of section 67. The appellant ....

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....ying a provision to condone the delay. If there is possibility of more than one construction, probably this court would have leaned in favour of placing such construction as to give benefit to the taxpayer in deserving cases. But, as already observed, the language employed in the Scheme and the features spelt out of the Scheme are crystal clear and do not admit of different interpretations. ....