Interest waiver requires genuine hardship, and a large interest burden alone does not justify interference with discretionary refusal.

Waiver of interest under Section 220(2A) of the Income-tax Act depends on proof of genuine hardship, circumstances beyond the assessee's control, and cooperation in recovery proceedings. The Court held that a large interest burden, even where it exceeded the tax demand, did not by itself establish genuine hardship. The assessee's financial capacity and corporate backing were relevant factors, and the authority's conclusion that the statutory conditions were not satisfied was a plausible exercise of discretion. No perversity or legal error was shown to warrant interference under Article 226, so the refusal to waive interest was upheld.

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Issues: Whether the refusal to waive interest under Section 220(2A) of the Income-tax Act, 1961 was vitiated by error in finding that the assessee had not shown genuine hardship.

Analysis: Section 220(2A) permits waiver of interest only when the assessee establishes genuine hardship, that the default was due to circumstances beyond control, and that cooperation was extended in recovery proceedings. The Court held that the mere magnitude of the interest burden or the fact that it exceeded a multiple of the tax demand did not by itself establish genuine hardship. The petitioner's association with a global conglomerate and its financial capacity were relevant considerations, and the authority's view that the statutory conditions were not satisfied was a plausible exercise of discretion. No perversity or legal error was shown to justify interference under Article 226 of the Constitution of India.

Conclusion: The rejection of waiver was upheld and the challenge failed.

Ratio Decidendi: Waiver of interest under Section 220(2A) of the Income-tax Act, 1961 is discretionary and can be interfered with only if the authority's conclusion on genuine hardship and the other statutory conditions is unreasonable or perverse.

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