2002 (12) TMI 63

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....r the department. The petitioner has challenged the impugned order of the Commissioner of Income-tax under section 273A of the Income-tax Act, 1961, dated July 19, 1984, annexure 2 to the petition. In this petition we are only concerned with the claim of waiver of interest under section 139(8) which has been denied by the Commissioner. The Commissioner has stated in his order that the Income....

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....ssioner has to take into consideration the conditions mentioned in that provision, but he cannot take into account factors or reasons which are extraneous to those conditions specified in the provision. In the present case the reasons given for rejecting the petitioner's application for waiver of interest under section 139(8) are not those Mentioned in clause (c) of section 273A(1). Learned cou....