Benefit of Sec.273A(1).

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..... is made simultaneously on the same date and not when the disclosures for different years is made on different dates, was considered by the Board in consultation with the Ministry of Law and accordingly instructions No. 1823 dated 1-8-89 and No. 1841 dated 26-3-90 were issued by the Board. It was stated that the disclosure made for different assessment years at different times cannot be clubbed to .....

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..... consideration of the issue and the judgments of various High Courts it has been decided that where a petition u/s 273A is made by an assessee for different assessment years at one point of time, the Commissioner may decide the question of waiver/reduction of interest/penalty for all the assessment years involved, irrespective of the dates of filing of the returns for those assessment years. For th .....

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