https://www.taxtmi.com/caselaws?id=165176 Unexplained delay in filing a writ petition may justify refusal of relief, but the court must assess the surrounding circumstances, including prior pursuit of revision; the petition was not rejected on delay. Dismissal of a revision does not cause merger of the underlying Income-tax Officer's order, because it is only a refusal to exercise revisional jurisdiction; the merger objection was rejected. On interpretation of section 18A, the proviso permitting reduction or waiver of interest applied only to the distinct class covered by section 18A(6) and could not be extended to the mandatory scheme in section 18A(8); rule 48 could not enlarge that discretion. The challenge to the levy of penal interest therefore failed. en-us Fri, 07 Nov 1958 00:00:00 +0530 Thu, 04 Sep 2014 19:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=165176 Unexplained delay in filing a writ petition may justify refusal of relief, but the court must assess the surrounding circumstances, including prior pursuit of revision; the petition was not rejected on delay. Dismissal of a revision does not cause merger of the underlying Income-tax Officer's order, because it is only a refusal to exercise revisional jurisdiction; the merger objection was rejected. On interpretation of section 18A, the proviso permitting reduction or waiver of interest applied only to the distinct class covered by section 18A(6) and could not be extended to the mandatory scheme in section 18A(8); rule 48 could not enlarge that discretion. The challenge to the levy of penal interest therefore failed. Case-Laws Income Tax Fri, 07 Nov 1958 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=165176