9911796707
TMI Blog2004 (12) TMI 57X X X X Extracts X X X X X X X X Extracts X X X X ..... (iii) to warrant the exercise of discretion conferred under section (2A) of section 220 of the Act to waive the amount of interest payable - We find that sufficient reasons have been given in support of the conclusions arrived at by the learned Commissioner in his order under appeal. Order impugned is a reasoned one and does not suffer from any legal infirmity. The petitioner, having failed to sat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... was paid by the assessee under the said sub-section. Under sub-section (2A) of section 220 of the Act, power has been conferred upon the Chief Commissioner or Commissioner to reduce or waive the amount of interest paid or payable by an assessee under sub-section (2) of the Act, if the Commissioner is satisfied that: (i) payment of such amount (has caused or) would cause genuine hardship to the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the same in accordance with law, or that the decision is founded on irrelevant considerations eschewing from consideration the relevant material on record or the same is perverse or in violation of principles of natural justice. It is the contention of Mr. Janardhan Raju, learned counsel for the assessee, that the order impugned suffers from non-application of mind and that the contentions raise ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... een read before us by learned counsel for the respective parties. We find that it is a reasoned order and does not suffer from any legal infirmity. From the material on record and more particularly, the averments made by the petitioners in the two representations made before the Commissioner, we are not satisfied that the petitioner has fulfilled the conditions (i) and (iii) to warrant the exercis ..... X X X X Extracts X X X X X X X X Extracts X X X X
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