Interest Waiver Under Income Tax Act Section 220(2A) Not Automatic; Disputes Don't Justify Non-Levy or Waiver.

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....Waiver of interest u/s 220(2A) - Levy of interest is mandatory - Merely raising the dispute before any authority cannot be a ground not to levy the interest and/or waiver of interest u/s 220(2A). Otherwise each and every assessee may raise a dispute and thereafter may contend that as the assessee was bona fidely litigating and therefore no interest shall be leviable. - SC....