2005 (7) TMI 89

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....Commissioner of Income-tax seeking waiver of interest and penalties with regard to the assessment years 1976-77, 1977-78, 1978-79, 1979-80, 1980-81, 1981-82, 1982-83, 1983-84, 1984-85, 1985-86 and 1986-1987, as per the provisions of section 273A of the income-tax Act, 1961. The Commissioner of Income-tax by his order dated March 21, 1990 granted relief only for the assessment years 1980-81 and ....

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....the Commissioner of Income-tax cannot grant any further reliefs for other assessment years. In the above provision, the relevant words are "such order relates to one or more assessment years". Therefore the Commissioner of Income-tax is entitled to grant the relief with regard to penalty and interest as a one time measure, but not subsequently. In the instant case there was one application for sev....