2000 (6) TMI 21

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....the first respondent. On December 19, 1985, there was a search in the residential premises of the petitioner and also in the hospital run by him. At the time of search, some cash and documents were seized. After search, revised returns were filed and exhibit P-1 is the statement showing additional income, additional tax and interest charged and penalty imposed. The revised tax paid as per the revi....

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....(has caused or) would cause genuine hardship to the assessee ; (ii) default in the payment of the amount on which interest (has been paid or) was payable under the said sub-section was due to circumstances beyond the control of the assessee ; and (iii) the assessee has co-operated in any inquiry relating to the assessment or any proceeding for the recovery of any amount due from him." The Co....

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.... the assessment years 1980-81 to 1985-86. Thus, the total payments came to Rs. 80,72,790 leaving a balance of Rs. 83,09,320, and, therefore, it is not correct to say that the payment of interest under section 220(2) will cause genuine hardship to the assessee. The assessee's argument is that a major part of the suppressed income was invested in the hospital building and, therefore, it is not readi....