9911796707
TMI Blog2013 (2) TMI 427X X X X Extracts X X X X X X X X Extracts X X X X ..... ault in making payment - It was after two unsuccessful attempts that the assessee again approached the CIT which was again rejected on the ground of non co-operation - Power conferred under Section 220 (2A) is not a power which could be invoked in a recurring manner on every change in circumstance – The first application having been considered by the competent authority and rejected; there was no ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... under Section 148 for the years in which no return was filed. For the subsequent years due to non co-operation of assessee, assessment was completed under Section 144 of the Income Tax Act. The assessment as such is not the subject of challenge in the above writ petition and the petitioner claims only waiver of interest levied under Section 220 invoking the power conferred under Section 220 (2A). ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , who is the petitioner herein has challenged Ext.P6 order as one passed rejecting the invocation of the powers under Section 220 (2A). I find that the petitioner had approached the Commissioner of Income Tax invoking powers under Section 220 (2A) of the Act with an earlier petition which was rejected by Ext.P2 finding that the petitioner has not paid the amounts demanded as tax and hence the peti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sioner of Income Tax by Ext.P5 which was again rejected on the ground of non co-operation by Ext.P6. In my opinion, the power conferred under Section 220 (2A) is not a power which could be invoked in a recurring manner on every change in circumstance. The first application having been considered by the competent authority and rejected by Ext.P1; there was no scope for any further application for t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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