Section 220(2A) interest waiver upheld where delayed demand, genuine hardship, and full cooperation satisfied all statutory conditions.

Interest waiver under Section 220(2A) was justified where the tax demand arose from an old assessment year, was served long after the firm had dissolved, and the assessee showed immediate payment on demand together with cooperation in recovery. Those facts supported genuine hardship, default beyond the assessee's control, and full cooperation, satisfying all three statutory conditions for waiver. On that basis, rejection of the waiver application was not sustainable.

---

---

Issues: Whether the assessee was entitled to waiver of interest under Section 220(2A) of the Income-tax Act, 1961 on the facts of the case.

Analysis: The demand related to an old assessment year, the tax arrears were served only many years after dissolution of the firm, and the petitioner stated that he was unaware of the arrears and had no records because the firm had long since ceased to function. The amount was paid immediately on demand, and the petitioner cooperated in the recovery proceedings. On these facts, the delay in recovery and the surrounding circumstances established genuine hardship, default beyond the assessee's control, and cooperation in the proceedings.

Conclusion: The assessee satisfied all three conditions for waiver of interest under Section 220(2A), and the rejection of the waiver application was not sustainable.

---