Scope of Sec.273A(4).

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....at:- (i) to do otherwise would cause genuine hardship to the assessee having regard to the circumstances of the case, and (ii) the assessee has cooperated in any inquiry relating to the assessment or in any proceeding for the recovery of any amount due from him. 2. The advice of the Ministry of law stating that unless a penalty is levied, there cannot be any proceedings under sub-section(4) of ....

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.... paid, there can be no case of any genuine financial hardship in respect of the payments already made. The question of waiver or reduction should, therefore, be considered only in respect of the amount which remains payable by the assessee. 5. However there may be cases where after application for waiver or reduction u/s.273(4) has been filed before the CIT action for recovery of demand in respec....