Writ interference with partial waiver of tax interest refused where authority applied CBDT notifications and exercised discretion properly.

Partial waiver of statutory interest under the Income-tax Act was upheld because the competent authority had applied the relevant CBDT notifications and exercised discretion on the facts. Waiver under Section 234A was granted up to the month in which the TDS certificate was issued, and waiver under Section 234B up to the date of the last disbursement of compensation. The court found no illegality, perversity, or error in that exercise of discretion, so writ interference was not justified and no further relief was warranted.

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Issues: Whether the order granting only partial waiver of interest under Sections 234A and 234B of the Income-tax Act, 1961 called for interference in writ jurisdiction.

Analysis: The relief sought concerned waiver of statutory interest for assessment years arising from enhanced compensation received in land acquisition proceedings. The competent authority had already granted waiver under Section 234A up to the month in which the TDS certificate was issued, and under Section 234B up to the date of the last disbursement of compensation. The court found that the authority had considered the relevant CBDT notifications, applied the governing conditions, and exercised discretion on the facts without illegality, perversity, or error warranting judicial interference.

Conclusion: The partial waiver order was upheld and no further relief was warranted.

Final Conclusion: The writ petition failed because the impugned order reflected a proper exercise of statutory discretion and did not justify interference under writ jurisdiction.

Ratio Decidendi: Interference in writ jurisdiction is not warranted where the competent authority has granted waiver within the framework of the applicable CBDT notifications and has exercised discretion on relevant facts without illegality or perversity.

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