1997 (8) TMI 67

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..... . The Deputy Commissioner of Income-tax, Range IV, passed an order of assessment against the petitioner raising a demand of Rs. 9,53,42,953 on account of income-tax and Rs. 6,81,64,603 on account of interest making a total of Rs. 16,35,07,556. The petitioner has filed an appeal against the order of assessment. The petitioner also moved an application under section 220(6) of the Act before the As .....

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..... cted by way of tax at source, credit whereof has not been allowed to the petitioner while passing the impugned orders though the attention of the authorities was specifically invited to it; secondly, that the Central Board of Direct Taxes has issued circulars, the directions contained wherein have not been kept in view by both the authorities though the attention of both the authorities was specif .....

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..... the case, we are of the opinion that the ends of justice would be satisfied if the respondents are directed to dispose of the petitioner's application under section 220(6) of the Act afresh. For the foregoing reasons, the petition is partly allowed. Respondent No. 2, who is the Assessing Officer, shall afford the petitioner an opportunity of hearing and dispose of his application (annexure "P .....

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