Ravikumar Dhandhania v. ITO (2022) 447 ITR 726 / 214 DTR 194 (Mad.)(HC)

S. 220 : Collection and recovery-Assessee deemed in default-Interest on interest-Incorrect declaration of income-Liable to pay interests. [S. 139, 220(2) 234A, 234B, 234C, Art. 226]

The assessee failed to pay the interest in time. Instead, the assessee filed an application under section 220 of the Act, to waive the interest.  The application was dismissed on December 28, 2016. It was only thereafter the assessee paid the amount quantified in the demand notice dated January 30, 2015 issued under section 156. On a writ petition to quash the order and direct waiver towards interest due under section 220(2) the Court held that as the assessee had failed to pay the amount in time, the assessee was liable to pay the interest. (AY.2007-08)