confirming the action
of the learned AO of levying interest under Section 234B of the
Act.
6. On the facts, and in the circumstances ... confirming the action of the
learned AO of levying interest under Section 234B of the Act by
treating it as consequential in nature
Royalty, had remanded the question regarding levy of
interest u/s.234A , 234B and 234D back to this Tribunal for
consideration on merit ... India and Singapore. With
regard to levy of interest under section 234A , 234B and
234D of the Income Tax Act, as the case
Income Tax(Appeals) had erred in holding that interest u/s 234B was
not chargeable in this case by relying upon the decision ... ground no. 5 qua the interest was not chargeable under
Section 234B of the Act, The ld CIT(DR) relied upon the decision
facts & circumstances of the case, interest u/s 234B & 234 C of the
Act ought not to have charged on increase in total ... record. Assessee is aggrieved on the charging of interest u/s
234B / 234C of the Act on the increase in total income resulting from
retrospective
Appeals) erred in confirming the charging of
interest u/s 234B(3) of the Act.
4
Mumbai Mazdoor Sabha
ITA Nos.1371/Mum/2013 ... union.
8. Ground no. 2 is regarding levy of interest u/s 234B(3) of
the Income Tax Act.
9. We have heard
preferred by Department against the
issue of chargeability of interest u/s 234B of the act. It includes
one cross objection against reopening of assessment ... before the Tribunal. Regarding the issue
of levy of interest u/s 234B it is contested that revenue has filed
special leave petition before
Assessing
Officer to mention / levy / charge
interest under section 234B of the
Income Tax Act (hereinafter referred to
as "the Act" for short ... order that so far as the charging of the interest under section
234B of the Act is concerned, the same is consequential and
therefore
Assessing
Officer to mention / levy / charge
interest under section 234B of the
Income Tax Act (hereinafter referred to
as "the Act" for short ... order that so far as the charging of the interest under section
234B of the Act is concerned, the same is consequential and
therefore
Vijayaraghavan, learned counsel for the appellant submitted that Sections 234B and 234C operate on different fields. Interest u/s 234B is levied, if advance ... liable to pay advance tax and therefore levy of interest under Sections 234B and 234C is not justified.
10. Placing reliance on a decision
officer erred on facts and in law in levying interest
under section 234B and 234C of the Act especially when there was no
liability
