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    <title>2003 (4) TMI 89 - CALCUTTA High Court</title>
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    <description>Section 273A was treated as conferring a substantive power on the Commissioner to reduce or waive interest and penalty in appropriate cases, so an application under that provision was not a barred review but a request for reconsideration on merits. The authority had to examine the assessee&#039;s bona fides and whether relief was justified in the interests of justice, and could not refuse consideration merely by characterising the exercise as impermissible review. The rejection order was therefore unsustainable and was set aside, with directions to reconsider the waiver request on merits within the time directed.</description>
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      <title>2003 (4) TMI 89 - CALCUTTA High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=11873</link>
      <description>Section 273A was treated as conferring a substantive power on the Commissioner to reduce or waive interest and penalty in appropriate cases, so an application under that provision was not a barred review but a request for reconsideration on merits. The authority had to examine the assessee&#039;s bona fides and whether relief was justified in the interests of justice, and could not refuse consideration merely by characterising the exercise as impermissible review. The rejection order was therefore unsustainable and was set aside, with directions to reconsider the waiver request on merits within the time directed.</description>
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