SHIV SHANKER SITARAM Vs. INCOME TAX APPELLATE TRIBUNAL

JUDGEMENT

(1.) THIS petition under Article 226 of the Constitution has prayed for a number of reliefs. One of them is for setting aside the order of the Commissioner of Income-tax dated September 19, 1985, by which penalty was reduced or waived by 50% under Section 273A(4) of the Income-tax Act, 1961.

(2.) SECTION 273A(4) of the Income-tax Act confers discretion on the Commissioner to reduce or waive the amount of any penalty payable by the assessee under this Act, if he is satisfied that--