D. Murugesan, J.

The appellant-M/s Rayala Corporation Private Limited is engaged in the business of manufacture and sale of typewriters and manufacture and supply of defence equipments/components to various defence establishments in the country. In respect of levy of interest under Section 216 of the Income Tax Act and for waiver for the assessment years 1978-79 and 1980-81, the matter landed before the Settlement Commissioner who, by order dated 30.12.92, remitted the matter to the assessing authority, and the assessments were completed on 12. 93 and 22. 94 respectively.

2. In terms of sub-section (3) of Section 264 of the Income Tax Act, the assessee is entitled to prefer a revision within a period of one year from the date of the assessment order. However, without availing the remedy of filing revision petition, the appellant-assessee approached this Court by filing W.P.Nos.21111 to 21113 of 1994. By order dated 212. 2000, this Court, while dismissing W.P.No.21111 of 1994 as infructuous, disposed the remaining two writ petitions with the following directions:-

"However, the petitioner is given liberty to approach the Commissioner of Income Tax for waiver of interest un