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2. The facts of the case are briefly stated hereunder :

One Steel Rolling Mills of Hindusthan Private Limited and Apeejay Structural Private Limited were amalgamated into one company, namely, the writ petitioner herein. The subject-matter of the writ petition relates to the assessment years 1973-74 and 1974-75. Interest is sought to be realised under Section 220 of the Income-tax Act, 1901 (in short "the Act" hereinafter). So the writ petitioner herein filed an application for waiver of interest under Section 220, Sub-section (2A) of the Act. In the application it was stated that the predecessor-in-interest of the writ petitioner filed returns showing net loss of Rs. 18,40,580 on August 14, 1973. Thereafter, a revised return was filed on November 25, 1975, showing net loss of Rs. 1,62,949. The Income-tax Officer completed the assessment on a total income of Rs. 19,20,560 on March 2, 1977, by making huge intangible additions and disallowances. On appeal before the Income-tax Commissioner (Appeals) and before the Income-tax Appellate Tribunal the total income was reduced. The Income-tax Appellate Tribunal sent back the matter on certain points to the Commissioner of Income-tax (Appeals) on June 26, 1979, and the Commissioner of Income-tax (Appeals) in his turn sent back the matter to the income-tax Officer on April 14, 1986. Thus, the total income was reduced to Rs. 7,51,705 while giving effect to the appellate order under Section 251. The Assistant Commissioner of income-tax, without considering the merits of the case, imposed the demand payable of Rs. 2,93,943 and also charged interest under Section 215 of Rs. 2,04,142 and interest under Section 220, Sub-section (2A) of Rs. 6,84.158 thereby making total demand payable of Rs. 9,78,300, after adjustment of the payment of Rs. 2,03,943 on March 30, 1988, without any justified reasons.