Section 260A of the Income Tax Act, 1961—Appeal — Appeal to High Court— Revenue being a quasi judicial authority, while exercising its power of discretion vest in them under section 220(2A) has not acted judiciously with cogent and plausible reasons with supporting materials and without giving opportunity of being heard to assessee, therefore, High Court has no hesitation to hold that, the impugned order is not sustainable, accordingly, it is liable to be interfered with. The hardship faced by the assessee, need not be the mere hardship, but, it should be a genuine hardship; the undue hardship is normally related to economic hardship and undue means something which is not merited by the conduct of the claimant or is very much disproportionate to it. Here, in the case in hand, according to the assessee, the undue hardship faced by the assessee was that, there had been no business for four years consecutively, with the result, the assessee did not have any source to make the payment as demanded under section 220 and when that situation was prevailing, the assessee made an application for waiver explaining the hardship faced by the assessee as a genuine hardship which was rejected by revenue without giving opportunity of being heard, thus, issues was remanded back for reconsideration — TCV Engineering ltd. vs. ASSTT. CIT [2020] 269 TAXMAN 410 (MAD)