1993 (2) TMI 60

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.... M.. R. Bhatt, learned counsel, appears for the respondent and waives service of rule. Considering the limited scope of the controversy involved in this special civil application, we have taken it up for final disposal today itself. We heard learned counsel on both the sides, on the merits. The impeachment in this special civil application is of the order made by the respondent under section....

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....the other hand, it is perfectly justified. All that the respondent said on the question goes thus : "XXX. I have gone through the case records of the assessee and have considered the submission made on behalf of the assessee and given my careful consideration to the matter. I am of the view that the assessee deserves to get some relief, as the conditions laid down in section 18B of the Act for ....

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....nt proceeds to say that the petitioner deserves to get some relief. The provision set forth in section 18B of the Act gives the power or vests the power to reduce or waive when there is a satisfaction on certain factors. But, if the respondent chooses not to waive in full despite the satisfaction having been arrived at for waiver, there must be sound and convincing reasons expressed therefor. That....