2010 (10) TMI 43

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....-. The Assessing Officer by his order dated 29.3.1993 enhanced it to Rs. 20,55,490/-. 2. The assessee filed appeal against the aforesaid order. The Commissioner of Income Tax (Appeals) (CIT-A) allowed the appeal on 14.4.1993. 3. The Income Tax Department (the Department) filed appeal against the order of the CIT-A. It was partly allowed on 12.2.2007 and the income of the assessee was assessed to....

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....on. (i) That payment would cause genuine hardship to the assesee; (ii) Default for the payment was due to circumstances beyond control of the assessee; and (iii) The assessee has cooperated in any inquiry relating to assessment or any proceeding for recovery of amount due to him. 9. The CIT-A has not applied its mind on any of the aforesaid three conditions mentioned in section 220(2A) of the ....