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JUDGMENT L. Narasimha Reddy, J. - The subject matter of these three writ petitions is similar. Hence, they are disposed of through a common judgment. 2. The petitioners are the assessees under the Income Tax Act (for short the Act). There was some delay on their part in filing Income Tax Returns for the assessment year 1995-96. While there was default in payment of a portion of advance tax referable to the assessment year, there was deferment of payment of advance tax in respect of the other portion. Ultimately, the petitioners were assessed to tax and they were also placed under the obligation to pay the interest as provided for under Sections 234-A, 234-B and 234-C of Act. All of them approached the Commissioner of Income Tax, Hyderabad, respondent herein by way of revisions under Section 264 of the Act with a prayer to waive the interest payable under Sections 234-A, 234-B and 234-C of the Act. One day after the revisions were filed, the Central Government issued notification for enforcement of Kar Vivad Samadhan Scheme, 1998 (for short the Scheme), which provided for termination of the proceedings on payment of 50% of the tax arrears, that are the subject matter of the appeals or revisions. 3. The petitioners submitted applications before the respondent, before whom the revisions were pending with a prayer to extend the benefit under the Scheme. Through separate orders, dated 27.01.1999, the respondent declined to extend the benefit of the Scheme, observing that he does not have the power to waive the interest leviable under Sections 234-A, 234-B and 234-C of the Act. Another reason furnished by him was that the notice issued to the petitioners under Section 271(1)(c) of the Act proposing to levy penalty is also outside his powers. The said orders are challenged in these writ petitions. 4. Sri S. Ravi, learned senior counsel appearing for the petitioners submits that the Scheme was evolved by the Central Government with a view to put an end to unnecessary litigation, even while protecting the interest of revenue. He contends that once an appeal or revision is pending and the assessee is prepared to pay 50% of the tax arrears, as defined under the Scheme,…

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