2000 (11) TMI 14

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....Central Board of Direct Taxes, which empowers the Chief Commissioners and Directors-General (Investigation) to reduce or waive penal interest for late submission of a return of income, non-payment or inadequate payment of advance-tax, etc., reads thus: "(v) where the return of income is filed voluntarily without detection by the Income-tax Department and due to circumstances beyond the control ....

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....has been given in the application. The Commissioner has also recorded that he had heard the representative of the applicant regarding the applicability of the conditions mentioned in the circular and that the representative was unable to show the applicability of any one of those conditions. The criticism that the Chief Commissioner has relied on the order of the Commissioner, Trichy, is not a ....