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8.2 On the facts and in the circumstances of the case and in law the Learned AO has erred in non- considering the fact that deferred tax credited to profit and loss account is a specified adjustment as per Section 115JB of the Act. Ground No.9 - Erroneous levy of interest under section 234C of the Act 9.1 On the facts and in the circumstances of the case and in law, the learned AO has erred in computing consequential interest under section 234C of the Act, where the same is levied on the returned income and not on the assessed income. Hence the interest under section 234C charged against the Appellant is erroneous. The Appellant craves leave to add, alter, rescind and modify the grounds herein above or produce further documents, facts and evidence before or at the time of hearing of this appeal."

20. The issue raised by the assessee in ground No. 9 is that the AO has calculated the interest under the provisions of section 234C of the Act on the assessed income instead of return income. Accordingly, the ld. AR requested to give the appropriate direction to the AO for calculating the interest under section 234C of the Act as per the law. On the other hand, the ld. DR raised no objection if the direction is given to the AO for the calculation of the interest under section 234C of the Act on the return income. After hearing both the sides and perusal of the materials available on record, we direct the AO to recalculate the interest under section 234C of the Act at the return income as per the law. Hence, the ground of appeal of the assessee is hereby allowed for statistical purposes.

13.2. On the facts, and in the circumstances of the case and in law, the learned AO has failed to appreciate the fact that the consequential interest has arisen on account of erroneous additions made as mentioned above.

13.3. In view of the above, the Appellant prays that the learned AO be directed to delete the erroneous levy of interest under section 234B of the Act (being consequential in nature).

Ground No.14 - Erroneous computation of Interest under section 234C of the Act 14.1. Based on the facts and circumstances of the case and in law, the learned AO has factually and legally erred, in computing interest amounting to INR 11,13,121 under section 234C of the Act.

instead of return income. Accordingly, the ld. AR requested to give the appropriate direction to the AO for calculating the interest under section 234C of the Act as per the law. On the other hand, the ld. DR raised no objection if the direction is given to the AO for the calculation of the interest under section 234C of the Act on the return income. After hearing both the sides and perusal of the materials available on record, we direct the AO to recalculate the interest under section 234C of the Act at the return income as per the law. Hence, the ground of appeal of the assessee is hereby allowed for statistical purposes.