Section 20

Relief because of doubt or difficulty in recovery of tax (TPA 2nd Sch Para 13)

(1) Notwithstanding the provisions of this Act, the Commissioner may, with the prior approval of the Cabinet Secretary, in any case where he is of the opinion that there is– 
(a) impossibility, or undue difficulty or expense, of recovery of tax; or 
(b) hardship or inequity, 
refrain from assessing or recovering the tax in question and thereupon liability to the tax shall be deemed to be extinguished or the tax shall be deemed to be abandoned or remitted, as the case may be.

 (2) In any case which has been referred to him and where he considers it appropriate, the Cabinet Secretary may, in writing, direct the Commissioner – 
(a) to take such action as the Cabinet Secretary may deem fit; or 
(b) to obtain the directions of the court upon the case

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