Interest waiver under income tax law sustained where land acquisition award provided compensation details and writ interference was unwarranted.

Where compensation, solatium and interest had already been fixed in the land acquisition award, there was no difficulty in filing the return, so refusal to waive interest under sections 139(8) and 217 of the Income-tax Act was not shown to be unreasonable or irrelevant. The High Court found no basis for writ interference with the Commissioner's decision under section 264, as the recorded reasons for declining relief for the later period were sustained on the available facts. Relief was therefore not granted.

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Issues: Whether the Court should interfere with the Commissioner's refusal to grant relief from interest levied under section 139(8) and section 217 of the Income-tax Act, 1961 in proceedings under section 264 of the Act.

Analysis: The petitioner's land had been acquired and the award had already specified the relevant amounts of compensation, solatium and interest. On that basis, there was no difficulty in filing the return. The reasons recorded by the Deputy Commissioner and affirmed by the Commissioner for declining waiver of interest for the later period were found to be neither unreasonable nor irrelevant, and no ground was shown for exercise of writ interference.

Conclusion: The refusal to interfere was upheld and the petition was dismissed.

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