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of Petitioner failed to establish non-payment of tax demanded was beyond their control. CC reasonably exercised powers u/s 220(2A) after considering relevant circumstances and material on record. Factual findings supported by evidence, no perversity. Chander Prakash Jain case distinguishable on facts, not involving Section 220(2A). HC does not exercise appellate jurisdiction. All three preconditions for waiver u/s 220(2A) not met. Petition dismissed.
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