@rohit, as per my view:-
(1) Perjury on affidavit needs to be filed immediately (in first available opportunity - alongwith the WS) - I myself filed it alongwith WS to Divorce u/s 13(1)(i-a) filed by my wife. I myself filed WS + Perjury + Order VII Rule 11 + Order X
(2) Perjury regarding Court Record Tampering needs to be filed immediately on knowing about it. If it happens after some dates/months/years then flile it that time. n my case, I filed Perjury before even WS to DVC because there was court record tampering & even the MM had her signs on it.
(3) Regarding a lot of other evidences remember these two situations viz., (a) Civil Case WS, & (b) Criminal Case WS
(A) CIVIL CASE:- In Civil Case, file almost all of the evidences (hold away some of the trump cards or game changers evidences) - when u hold such evidences MUST MENTION within assertions & also within prayer that, your right to present such trump cards evidences shall be reserved.
(B) CRIMINAL CASE/ 498A - Do NOT file any evidences here. Just Deny deny & let them beg in your feet to compromise because thru CIVIL CASE they will extract these evidences from u & in criminal case their feet will tremble with passage of time because they will know that perjury filed by u in a criminal case would mean a 5 year jail (conviction) for all those false case filers & witnesses in support thereof.
(C) DVC - Here I suggest to file WS like in a CIVIL case even though in Delhi it follows the CrPC.
REMEMBER:- Write unclean hands etc within the WS & wait for their rejoinder. After rejoinder you can file perjury or wait for further stages. (after their admission)