Interest waiver under tax law depends on statutory conditions, and equity cannot override the fiscal framework.

Waiver of interest under Section 119(2)(a) was unavailable because the assessee had filed a return disclosing the property sale, but had not disclosed the capital gains liability, so the case did not fall within unavoidable circumstances preventing timely filing. The CBDT communication was treated as a statutory order under Section 119(2)(a) and binding on the Chief Commissioner, leaving no scope for an equity-based reduction outside the fiscal scheme. On that basis, the request for interest waiver was rejected.

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Issues: Whether the assessee was entitled to waiver of interest under Section 119(2)(a) of the Income-tax Act, 1961, and whether the CBDT order applied to his case.

Analysis: The claim for waiver failed because the assessee had filed a return disclosing the property sale but had not disclosed liability on capital gains, so the case was not one where the return could not be filed due to unavoidable circumstances. The CBDT communication was treated as a statutory order issued under Section 119(2)(a), binding on the Chief Commissioner. The request for an equitable reduction of liability was rejected because waiver is governed by statute and the High Court cannot create an equity-based exception that overrides the fiscal framework.

Conclusion: The assessee was not entitled to waiver of interest, and the challenge to the refusal was rejected.

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