1999 (1) TMI 31

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..... orders passed under section 220(2A) of the Income-tax Act, 1961 (hereinafter referred to as "the Act"). As against exhibit P-1 assessment order determining the tax of Rs. 14,445, the petitioner has preferred an application, exhibit P-2, dated April 11, 1983, under section 154 of the Act for rectification. In that it is stated that a sum of Rs. 9,763 is levied as interest under section 139(8) of .....

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..... derable difficulty in paying the amount. The Commissioner in exhibit P-7 order found that there is nothing to show that the petitioner was in financial difficulties or that further payment by way of interest would cause genuine hardship to him. I do not find any illegality in the said finding since the petitioner has not established his genuine hardship as required under sub-section (2A) of sectio .....

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..... iver of interest under section 217 of the Act. As this was not conceded in the memorandum of his revision application also the relief was claimed. It is now submitted that as against the order refusing to grant the relief under section 217 of the Act an appeal has to be preferred. It is too hard to drive the petitioner to an appeal at this stage. In the above circumstances the claim in so far as s .....

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