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TMI Blog2012 (4) TMI 415X X X X Extracts X X X X X X X X Extracts X X X X ..... d by the assessee. Ext.P5 is an order passed by the 1st respondent rejecting the application made by the petitioner for waiver of interest, levied under Section 234A, B and C of the Income Tax Act. Ext.P6 is yet another one issued by the 1st respondent rejecting an application made by the petitioner for waiver of interest under Section 220(2) of the Income Tax Act. 2. Ext.P5 order is dealt with t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ment were due to unavoidable circumstances, no mention is made of such circumstances justifying the request for waiver. 3. The circumstances justifying the delay in payment of tax, are factual matters which are to be pleaded and established by the assessee. Ext. P4 is the application made by the assessee for waiver of interest. In Ext. P4 also apart from repeatedly stating that default has occurr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... re again, apart from the pleading that the non-payment of tax was due to reasons beyond the control of the assessee, the assessee has not established this factual question. Further the ingredients of the other conditions specified in Section 220(2)(a) also are not established. Therefore, the finding to that effect rendered by the 1st respondent in Ext.P6 order cannot be said to be illegal. 5. In ..... X X X X Extracts X X X X X X X X Extracts X X X X
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