Dismissing the petition the Court held that in law, equity would be subservient to; and, could not override; statute .Rejection  of petition for waiver of interest is held to be justified .Court also held that ,when regulatory mechanisms in fiscal legislation govern a situation; that cannot be visited in exercise of power under Article 226 and appellate jurisdiction through an intra-court appeal since that would be in defeasance of statutory impact of fiscal legislation in nature of the Income Tax Act, 1961.