dated 9 th November 2022 seeking waiver
of interest charged under Section 234C of the Income Tax Act, 1961
(" Income ... amount of Rs.3,88,59,353/- charged under
Section 234C of the Income Tax Act. Such is the limited issue for
consideration before
under sections 234B and
234C of the Act respectively on the additional income assessed pursuant to the
Advance Pricing Agreement ("APA").
2. That ... case and in law, the levy of interest
under sections 234B and 234C of the Act on the additional income assessed
22
pursuant
under sections 234B and
234C of the Act respectively on the additional income assessed pursuant to the
Advance Pricing Agreement ("APA").
2. That ... case and in law, the levy of interest
under sections 234B and 234C of the Act on the additional income assessed
22
pursuant
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 ... learned AO has
erred in computing consequential interest under section 234C of the Act, where the
same is levied on the returned income
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 ... learned AO has
erred in computing consequential interest under section 234C of the Act, where the
same is levied on the returned income
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 ... learned AO has
erred in computing consequential interest under section 234C of the Act, where the
same is levied on the returned income
appreciate that notwithstanding the mandatory
nature of interest u/s 234B & 234C of the Act, the law
of the land requires the Assessing Officer ... charge
interest u/s 234B & 234C by specific and clear order u/s
143(3) after applying his mind.
2. That on the facts
wholly unjustified in holding charging of interest u/s 234C as
consequential since such interest is chargeable on returned income only
and in view ... wholly unjustified in holding charging of interest u/s 234C as
consequential since such interest is chargeable on returned income only
and in view
Intimation) and the CPC enhanced the
interest u/s.234C of the Act to the tune of Rs.1,48,04,175/- whereas
assessee computed ... interest u/s.234C of the Act at Rs.29,51,188/-.
Such a demand has been determined on account of levy of interest
wholly unjustified in holding charging of interest u/s 234C as
consequential since such interest is chargeable on returned income only
and in view ... wholly unjustified in holding charging of interest u/s 234C as
consequential since such interest is chargeable on returned income only
and in view
