Whether genuine hardship should be existing at time of assessment or levy of penalty or at time of making of application under section 273A(4)

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..... 1. Section 273A(4) of the Income-tax Act, 1961 provides that the Commissioner of Income-tax may, on an application by an assessee, and after recording his reasons for so doing, reduce or waive the amount of any penalty payable by the assessee under the Income-tax Act or stay or compound any proceedings for recovery of any such amount if he is satisfied that : (i) to do otherwise would cause .....

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