The petitioners have filed valid declaration , however the petitioners could not pay the\u00a0 tax due to death of director of the company who was looking after the taxation and affairs\u00a0 of the company on July , 20, 2021 . The petitioners have filed writ petition\u00a0 seeking direction to the respondents to accept the declaration filed by the petitioners . Allowing the petition the Court held that ,\u00a0 The\u00a0Direct Tax Vivad Se Vishwas Act, 2020\u00a0is a beneficial piece of legislation with the avowed object to provide for resolution of disputes whereby the assessee is permitted to settle the dispute pending before any appellate authority, resulting in reduction in litigation and generation of timely revenue for the Government. Consequently, being a beneficial or a remedial statute, the provisions of the 2020 Act must be interpreted in a manner which advances the purpose for which it is enacted and a strict interpretation of this Act will defeat the very purpose for which it was introduced by the Legislature. The 2020 Act is a beneficial piece of legislation the provisions of which must be interpreted liberally. In recognition of intermittent lock down on account of the Covid-19 pandemic the scheme was amended several times to extend the deadline for payment. The power of the High Court under article\u00a0226\u00a0of the\u00a0Constitution of India\u00a0to grant relief in extraordinary and exceptional circumstances cannot be taken away or curtailed by any legislation. Delay was condoned\u00a0 and directed to\u00a0 treat declaration as valid and accept the payment with interest.<\/p>\n","protected":false},"excerpt":{"rendered":"
Direct Tax Vivad Se Vshwas Act, 2020 <\/p>\n
S. 4: Declaration \u2013 Delay in payment of tax – Condonation of delay – Object of legislation beneficial and to reduce litigation \u2014 Rejection of belated declarations filed due to death of director of assessee – Delay in payment of disputed amount \u2014 Delay was condoned \u2013 Directed to treat declaration as valid and accept the payment with interest- Interpretation of statutes -Beneficial legislation \u2013 Liberal interpretation . [ S. 5, 10(2), 67(2), Art , 226 ] <\/p>\n","protected":false},"author":3,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"jetpack_post_was_ever_published":false,"_jetpack_newsletter_access":"","_jetpack_dont_email_post_to_subs":false,"_jetpack_newsletter_tier_id":0,"_jetpack_memberships_contains_paywalled_content":false,"_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[21],"tags":[],"class_list":["post-32909","post","type-post","status-publish","format-standard","hentry","category-income-tax-act"],"acf":[],"jetpack_featured_media_url":"","jetpack_shortlink":"https:\/\/wp.me\/p9S2Rw-8yN","jetpack-related-posts":[],"jetpack_sharing_enabled":true,"_links":{"self":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/32909","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/comments?post=32909"}],"version-history":[{"count":1,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/32909\/revisions"}],"predecessor-version":[{"id":32910,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/32909\/revisions\/32910"}],"wp:attachment":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/media?parent=32909"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/categories?post=32909"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/tags?post=32909"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}