2005 (7) TMI 89

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....aiver 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 1981-82 and declined to grant relief f....

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....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 several assessment years, hence the Commissione....