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2014 (1) TMI 1041 - HC - Income TaxWaiver of penalty and interest u/s 273A - Whether the petitioner had made satisfactory arrangements for the payment of tax - Held that:- The petitioner had been unable to show that a satisfactory arrangement had been made for payment of tax and interest for all the years except for one year i.e. 1981 - The learned CIT was of the view that penalty amounts and total dues under Section 220 had to be paid or arranged - The language of the provision i.e. Section 273A(3) of the Act does not talk of one year but of one instance - In this case clearly the view of the Commissioner proceeded on the assumption that the relief could be given one time for one year - the inclusion of any amount over and above the tax and interest payable, such as penalties determined under various provisions as well as the assumption that such amount is collectively payable is without the authority of law. The assessee has been able to demonstrate that payment of tax and interest had been made in respect of the years 1981-82 to 1984-85. The impugned order is set aside in totality in respect of these assessment years
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