Operating profit is Relevant in deciding Interest Waiver Application

The fact that the Assessee is a part of “DuPont”, a global conglomerate which had in 2011 $37.96 billion in net sales and $6.253 billion as operating profit , cannot be said to be an irrelevant factor in considering whether any genuine hardship0 was undergone by the Petitioner. Further, in comparison to the profitability of the Petitioner over the years, the amount paid by it towards interest under Section 220 (2) of the Act was merely $0.004 billion (approx). In the circumstances, the conclusion arrived at by the CIT that no genuine hardship can be said to have been caused to the Petition...