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Madhya Pradesh High Court (India) 2002 Indian Income Tax Act, 1961

2002 PTD 1225

Penalty Waiver or reduction of penalty
SHARADA PULLELA
Appellant
VS
COMMISSIONER OF INCOME-TAX
Respondent

Case Laws / Head Notes / Paras

Penalty Interest Waiver or reduction of penalty or interest Commissioner of Income-tax must decide application for such waiver or rejection on merits Rejection of application without application of mind is not valid Indian Income Tax Act, 1961,S.273A.
Section 273A of the Income Tax Act, 1961, itself contains criteria in clauses (a), (b) and (c) appearing in subsection (1) thereof for recording satisfaction about existence of the conditions contained therein and taking a decision in the matter.
Held, that, in the instant cases, there was no application of mind by the Commissioner of Income-tax to the requirements of section 273A. The rejections of applications under section 273A were not valid.