TMI Blog2006 (3) TMI 113X X X X Extracts X X X X X X X X Extracts X X X X ..... he petitioner's request for waiver of interest levied under section 220(2) of the Income-tax Act, 1961 for the assessment year 1993-94. The petitioner is a Government company engaged in advance of loan, conducting kuries, etc. The petitioner claimed deduction of huge wage arrears paid to the employees for the assessment year 1993-94. However, the claim was disallowed holding that the liability a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... year 1994-95 and right to request for adjustment of the refunds against demand for 1993-94, the petitioner did not choose to file the returns for 1994-95 immediately or within the 35 days' time available for payment of demand raised for the assessment year 1993-94. A belated return for 1994-95 was made on August 23, 1996, and the Assessing Officer on the very same date processed the return under ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lished the other grounds, namely, that the payment of interest would cause genuine hardship to the assessee and that non-payment of tax demanded in time was under the circumstances beyond the control of the assessee. The assessee's counsel submitted that the Commissioner's observations are out of place because the assessee is a Government company with lot of limitations and liquidity problems. The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the Act. Of course, out of the total payment of Rs. 1.5 crores, around Rs. 63 lakhs accounts for interest under sections 234B and 234C of the Income-tax Act. It is not known whether the petitioner applied for waiver of this interest and if it applied whether any relief is granted. In any case, in view of the foregoing discussion, there is no scope for waiving interest which the petitioner coul ..... X X X X Extracts X X X X X X X X Extracts X X X X
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