Rejecting the petition the Court held that   the assessee had failed to make out any case with the non-payment of the tax demanded in time under circumstances beyond his control. There was significant ambiguity about the sources from which the assessee had arranged the amount to pay part of the tax. However, no case was made out that the assessee could not pay the taxes because the investments, gold and diamonds were seized in 2007. The investments were not substantial in the tax and interest demand context. The Chief Commissioner had applied his mind to the relevant circumstances and had passed a reasoned order rejecting the application under section 220(2A) for waiver of interest. Considering the limited scope of judicial review, no case was made out to interfere with the order rejecting waiver of interest under section 220(2A). Order of rejection was affirmed. (AY. 2002-03 to 2008-09)