Interest waiver under income-tax law upheld where hardship plea failed and relevant financial factors were duly considered.

Section 220(2A) interest waiver requires the authority to consider the assessee's financial position, hardship, and relevant surrounding circumstances, and the decision will not be interfered with unless it is shown to be unreasonable or based on irrelevant considerations. On the facts noted, the Commissioner considered the assessee's immovable properties, rental and agricultural income, and prior adjustments against earlier dues before refusing waiver. As the record showed application of the relevant factors and no material indicating arbitrariness or unjustness, the refusal to waive interest was upheld.

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Issues: Whether the refusal to waive interest under section 220(2A) of the Income-tax Act, 1961 was vitiated by unreasonableness or failure to consider genuine hardship.

Analysis: The assessee sought waiver of interest on the ground of financial difficulty and personal hardship. The Commissioner rejected the request after taking into account the assessee's immovable properties, rental income, agricultural income, and the fact that adjustments had already been made against earlier dues. The order disclosed consideration of the relevant circumstances, and no irrelevant factor was shown to have influenced the decision. The material on record did not establish that the decision was unjust or unreasonable.

Conclusion: The refusal to waive interest was upheld and the challenge failed.

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