2005 (7) TMI 89

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..... d for other assessment years. - In the instant case there was one application for several assessment years, hence the Commissioner of Income-tax ought to have granted relief for all assessment years and not restricted to only two assessment years. - Hence we hold that the petitioner is entitled to waiver of interest and penalty for the assessment years 1982-83 to 1986-87, accordingly the responden .....

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..... At the relevant time, the relevant section 273A(3) of the Income-tax Act, 1961 read as under: "Section 273A.(3) Where an order has been made under sub-section (1) in favour of any person, whether such order relates to one or more assessment years, he shall not be entitled to any relief under this section in relation to any other assessment year at any time after the making of such order." A .....

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