1998 (1) TMI 1

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....nt under section 220(2) of the Income-tax Act on account of default having been committed by the appellant in payment of income-tax within time. In order to avoid this levy, the appellant filed an application under sub-section (2A) of section 220 before the Central Board of Direct Taxes, inter alia, stating facts and reasons as to why the amount of interest which was payable should be reduced, if ....

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....t while rejecting the application the Central Board of Direct Taxes had given no reasons. The High Court observed, while dismissing the writ petition, that the order of the Central Board of Direct Taxes could not be said to be vitiated for this reason. When an application is filed under sub-section (2A) of section 220 the authority concerned is called upon to take a quasi-judicial decision. If ....

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....decision of the application may have repercussions with regard to the amount of interest which an assessee is required to pay it would be imperative that some reasons are given by the authority while disposing of the application. Mr. Salve, learned senior counsel for the appellant, has strongly relied upon the observations of this court in Siemens Engineering and Manufacturing Co. of India Ltd. v.....