2013 (2) TMI 427

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.... The petitioner challenges Ext.P6 order refusing to invoke the powers conferred on the first respondent for waiver under Section 220 (2A) of the Income Tax Act. The petitioner was a stock broker and on the claim that he had no sufficient income for the years 1990-91 and 1991-92, did not file any return of income. For the assessment year 1992-93, the petitioner filed returns however without nece....

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....e assessee and (iii) assesse's co-operation in any inquiry or any proceedings for recovery. The counsel for the petitioner would submit that the facts and circumstances of the case would amply evidence the satisfaction of all the above three conditions, thus entitling the case of the assessee to be one fit to be considered under Section 220 (2A). The counsel for the Revenue would however conten....

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....the Chief Commissioner ought to have considered the prayer of the petitioner favourably. However, contrary to what is submitted, I find that even the second application made by the petitioner invoking both Section 190 (2) as also 220 (2A) of the Income Tax Act was considered by the Chief Commissioner and the latter prayer was again rejected for non-co-operation evidenced by default in making pa....