Interest waiver requires a pre-existing jurisdictional ruling and payment of principal tax; excess demand interest may be refunded.

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....Clause 2(c) of the 2006 interest waiver/reduction scheme requires non-payment of tax to result from a jurisdictional High Court ruling that governed the taxpayer when advance tax was paid or the return was filed. A later ruling does not satisfy that condition, and waiver also requires prior payment of the principal income-tax demand. Challenges to the underlying interest liability cannot be pursued in proceedings confined to a waiver application. Interest under section 220(2) arises only after default in paying a demand served under section 156 within the prescribed period. Waiver rejection was sustained, while taxpayers may seek refund of excess section 220(2) interest if charged from the return-filing date.....