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The petitioner, an income-tax assessee, appealed against an order levying interest under section 234B of the Income-tax Act, 1961. The Commissioner of Income-tax rejected the petitioner's application to waive the interest, stating that he cannot interfere with the levy of interest. The court held that the statutory revision under section 264 of the Act cannot be sustained against the interest. The petitioner's waiver application is still pending, so the court disposed of the original petition without prejudice to the petitioner's right to pursue the waiver application.
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