Waiver application of the petitioner for waiver of interest  was rejected on the ground that the case of the company did not fall within any of the circumstances specified in the Central Board of Direct taxes Notification dt . 26-06-2006 being reference No .F.No. 400/29/2002 -IT(B)  , and further the company had sufficient liquidity to pay the advance tax and income tax therefore it cannot be stated that the Company encountered any hardship to pay the tax or file the returns on time. On writ the Court held that , though the assessee  was not specifically covered any of the situation contemplated in the notification, the assesseee  entitle for a partial relief dehors the notification , as the assessee was legally  Incapacitated for making any payment due to wound up . ( WP No. 12500 of 2010 dt 10-2 -2020) (AY. 1995 -96 , 1996 -97)