2015 (10) TMI 948

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....jeeva Reddy, who is said to be a partner of M/s S.V. Constructions, an agreement of sale was found, as per which, the petitioner was found to have individually paid an amount of Rs. 1,22,50,000/-, out of Rs. 4.9 lakhs, for purchase of landed property, along with three others and he has explained the source of income. Out of the total amount, which the petitioner has paid, the assessment officer accepted the petitioners contribution of Rs. 5,00,000/- and the balance amount of Rs. 1,17,50,000/- was treated as unexplained investment. Based on certain receipts, which were impounded during survey, an additional amount of Rs. 25,00,000/- was also brought to tax, on the ground that the petitioner along with others paid Rs. 5.9 crores, but not Rs. ....

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....x, rejected the petition. Hence the writ petition. 3. The impugned order reads as under: There are no reasonable grounds nor hardship exists in the instant case warranting waiver of interest as sought, hence the petition for waiver of interest is rejected. 4. The claim of the petitioner is that because of the circumstances beyond his control, which he has mentioned in the petition for waiver, he was unable to pay the amount due, within the period stipulated and that as he satisfies the three conditions under Section 220(2A) of the Act, he is entitled to be considered for waiver of interest. 5. The learned Standing Counsel for the respondents stated that though the impugned order does not contain reasons, the Department has filed....