9911796707
TMI Blog2016 (9) TMI 1559X X X X Extracts X X X X X X X X Extracts X X X X ..... taxes. After noting the factual circumstances in the said case, it was pointed out that if the circumstances have been considered to be unavoidable circumstances for the purpose of waiver of interest under section 234A, in the facts of the case, the same would have to be considered as unavoidable circumstances for the purpose of reduction/waiver of interest under sections 234B and 234C as well. Accordingly, whatever waiver granted under section 234A, shall also be extended with regard to waiver of interest under sections 234B and 234C of the Act. As noticed above, the respondent was satisfied with the fact that the petitioner has made out a case for waiver of interest under section 234A of the Act and the respondent recorded that it ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... due to the delay in getting the share income particulars from the firms, there was a delay in filing his individual return of income for the assessment year 1988-89 to 1991-92. Further, it is stated that as soon as he received share income particulars, he filed return of income on 28.07.1994 voluntarily. The said explanation given by the petitioner was found acceptable and reasonable cause for delay in filing the Return of Income and therefore, the respondent waived the interest charged under section 234A of the Act. However, for the interest under sections 234B and 234C of the Act, the authority did not refer to the reasons given by the petitioner nor his objections for waiver, but, stated that the circumstances mentioned in the Notificati ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rcumstances have been considered to be unavoidable circumstances for the purpose of waiver of interest under section 234A, in the facts of the case, the same would have to be considered as unavoidable circumstances for the purpose of reduction/waiver of interest under sections 234B and 234C as well. Accordingly, whatever waiver granted under section 234A, shall also be extended with regard to waiver of interest under sections 234B and 234C of the Act. 6.As noticed above, the respondent was satisfied with the fact that the petitioner has made out a case for waiver of interest under section 234A of the Act and the respondent recorded that it is a reasonable cause for delay in filing the return of income. Applying the reasons assigned by ..... X X X X Extracts X X X X X X X X Extracts X X X X
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