TMI Blog2017 (1) TMI 400X X X X Extracts X X X X X X X X Extracts X X X X ..... s that the reduction is for 90% of the interest on tax amount and also the entire amount of penalty and interest thereon. If such was the intention of the Legislature, definitely there was no reason to have specifically mentioned it, whereas what the Legislature has done was that after the word tax amount, a comma is inserted and thereafter the words 'and for the amount of penalty and interest thereon' is incorporated, which apparently indicates that the words “reduction of 90%” is on the interest on the tax amount as well as on the amount of penalty and interest thereon. A different view is not possible and therefore I do not think that the petitioner was justified in making such a demand - petition dismissed - decided against petitioner. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vit has been filed by the respondent inter alia stating that as against an order of assessment, petitioner had challenged the matter before the appellate authority who modified the order of assessment. Consequently appeal was filed which is pending before the Tribunal as TA No.6/2014. The petitioner gave intimation dated 23/12/2013 seeking the benefit under an amnesty scheme. When an intimation was given to the petitioner to remit certain amounts, the same was challenged by filing WP(C) No.5447/2014. This Court by judgment dated 11/3/2014 directed the 1st respondent to reconsider the application and inform the petitioner about the amount to be satisfied under the Scheme, pursuant to which the petitioner was intimated as per letter dated 2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mount of penalty and interest thereon. 5. In respect of amnesty scheme available in respect of demands relating to the period 1st April, 2000 to 31st March, 2005, the reduction granted is 90% of the interest on the tax amount and for the amount of penalty and interest thereon. The contention is that the reduction is for 90% of the interest on tax amount and also the entire amount of penalty and interest thereon. If such was the intention of the Legislature, definitely there was no reason to have specifically mentioned it, whereas what the Legislature has done was that after the word tax amount, a comma is inserted and thereafter the words ' and for the amount of penalty and interest thereon ' is incorporated, which apparently ..... X X X X Extracts X X X X X X X X Extracts X X X X
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