COMNR. OF SALES TAX, U.P. vs S/S NEW INDIA INSURANCE CO.LTD. — C.A. No. 2422/2000

Case Summary NOTE: The document provided is Civil Appeal 2421 of 2000 (Commissioner of Income Tax, Mumbai v. Anjum M.H. Ghaswala), NOT the case listed in your header (C.A. No. 002422/2000 - COMNR. OF SALES TAX, U.P. v. NEW INDIA INSURANCE CO.LTD.). This summary addresses the actual judgment document supplied. --- The Supreme Court held that the Settlement Commission under the Income-Tax Act has no power to waive or reduce statutory interest payable under Sections 234A, 234B, and 234C, despite being empowered to settle cases under Section 245D(4). The Court reasoned that these interest provisions are mandatory in nature and Section 245D(6)—which mentions interest—is merely procedural, establishing payment terms rather than granting waiver powers. The Court rejected arguments based on purposive interpretation and the Board's administrative powers under Section 119, finding the statutory language unambiguous. However, the Commission may grant relief within the scope of Board Circulars issued under Section 119. This case analysis is maintained by casestatus.in based on publicly available court records.