Interest waiver under Section 220(2A) requires recorded satisfaction on statutory conditions and a reasoned speaking order.

Section 220(2A) permits waiver or reduction of income-tax interest only if the competent authority records satisfaction that genuine hardship exists, the default arose from circumstances beyond the assessee's control, and the assessee cooperated in assessment or recovery proceedings. The exercise of this power is quasi-judicial and must be supported by reasons in a speaking order to withstand judicial review. An order granting waiver without independently testing the statutory conditions or recording reasons is unsustainable and requires fresh reconsideration in accordance with law.

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Issues: Whether waiver of interest under Section 220(2A) of the Income-tax Act, 1961 could be granted without recording satisfaction that all statutory conditions were fulfilled and without a speaking order.

Analysis: Section 220(2A) confers a limited power to reduce or waive interest only when the competent authority is satisfied that genuine hardship exists, the default was due to circumstances beyond the assessee's control, and the assessee cooperated in the assessment or recovery proceedings. The power is quasi-judicial and must be exercised judicially. A decision under the provision must be supported by reasons so that it can withstand judicial review. The order under challenge granted waiver merely by following an earlier decision, without examining whether the statutory conditions were met and without recording reasons.

Conclusion: The waiver of interest could not be sustained and was rightly interfered with. The matter was required to be reconsidered afresh in accordance with law.

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