2013 (1) TMI 161

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.... ADV. SRI.JOSE JOSEPH, SC, INCOME TAX       JUDGMENT Heard the learned counsel for the petitioner and the learned counsel for the respondents.   2. Petitioner challenges Ext.P3, an order passed by the 1st respondent on an application made by the petitioner for waiver of interest as provided under Section 220(2A) of the Income Tax Act, 1961. It is seen that....

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....gs.   4. Insofar as the absence of any other business or source of income is concerned, first of all, respondents themselves have no case that the petitioner had any other business or source of income. It is also the admitted case of the respondents that the entire properties of the petitioner are under attachment and that the interest liability of the petitioner was satisfied from out of ....

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.... least, prima facie, proved by the fact that the entire properties of the petitioner was under attachment and that the entire liabilities were subsequently cleared by making appropriation of the compensation amount.   Therefore, I am unable to uphold both the grounds relied on in Ext.P3 against the petitioner.   6. Learned counsel for the revenue contended that Ext.P3 order concern....