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Issues:
1. Application under section 273A of the Income-tax Act for waiver of interest and penalty. 2. Violation of principles of natural justice in passing the order. 3. Compliance with conditions precedent for invoking section 273A of the Act. Detailed Analysis: The petitioner filed income-tax returns for several assessment years and was aggrieved by the levy of interest under sections 139 and 217 of the Income-tax Act. The petitioner applied under section 273A of the Act for waiver of the interest. However, the respondent rejected the application citing non-compliance with the conditions stipulated in section 273A for waiver of penalty and interest. The respondent noted that the petitioner had not paid the taxes on the admitted income for certain years and had not made arrangements for payment of tax arrears for other years. The respondent found that the petitioner's filing of returns was prompted by a real estate investment, not genuine compliance with tax obligations. The petitioner argued that the order violated the principles of natural justice and should be set aside. The petitioner contended that taxes were paid based on the returns for most years, and therefore, interest should have been waived. The respondent, on the other hand, argued that there was no violation of natural justice and that the petitioner had not met the conditions precedent for invoking section 273A. The respondent relied on a judgment from the Kerala High Court to support this position. The court examined the contention of natural justice violation and found that the petitioner was represented by an authorized person during the proceedings, thus rejecting the argument of lack of opportunity to present the case. Regarding compliance with conditions precedent for invoking section 273A, the court noted that the petitioner had not paid taxes on admitted income for certain years and had not settled the tax differences for other years. The court referred to precedents to support the decision that non-compliance with conditions under section 273A precludes invoking its provisions. In conclusion, the court dismissed the writ petition, upholding the respondent's decision to reject the application under section 273A due to non-compliance with the statutory conditions. The court found no merit in the arguments of natural justice violation and upheld the decision based on legal precedents cited during the proceedings.
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