Held that  rejection of application by the Commissioner based on FAQ to exclude a genuine disputant of tax liability from the possibility of settlement under the 2020 Act was hyper-technical and bad in law. The interest as demanded under section 220(2A) of the 1961 Act which was 1 per cent. for every month of the period of delay as opposed to an application of rule 154 of the Companies (Court) Rules which provided for an interest ceiling at the rate of 4 per cent. interest for companies in liquidation, was a statutory benefit given to companies in liquidation. It could not be contended that the Commissioner was not qualified to account for the beneficial provisions for the assessee in liquidation though that was not the ground of rejection of the assessee’s declaration under the 2020 Act. The rejection of assessee’s declaration by the Principal Commissioner was to be set aside and the Commissioner directed to re-examine or reassess the assessee’s declaration and decide on its merits in terms of procedure envisaged under the 2020 Act read with its Rules. (AY.1984-85, 1985-86)