judgment of Honble Supreme Court in the case of CIT v. Kwality Biscuits Ltd. (2006) 284 ITR 434 in the case of computation under Section ... deptt. against the judgment of Karnataka High Court in the Kwality Biscuits Ltd. v. CIT . The effect of dismissal of the appeal is that
Supreme Court judgment relied upon in the case of CIT vs. Kwality
Biscuits Ltd. 284 ITR 434 (SC), related to Section 115J and not section ... Supreme Court on the case of CIT Vs. Kwality Biscuits Ltd.,284 ITR
434(SC) concluded that interest is not chargeable u/s 234B
Supreme Court in the case of
CIT vs. Kwality Biscuits Ltd. [284 ITR 434]. The Assessing Officer passed
order rejecting the rectification petition filed ... that the
Hon'ble Supreme Court in the case of Kwality Biscuits Ltd. (supra) has
merely dismissed the appeals filed by the Revenue
judgment of the Karnataka High Court in the case of Kwality Biscuits
Ltd. vs. CIT (supra) and, according to the Karnataka High Court, the profit ... 115J applied. This view of the Karnataka High Court in Kwality Biscuits Ltd.
(supra) was not shared by the Gauhati High Court in Assam Bengal
Supreme Court in the
case of CIT vs. Kwality Biscuits Ltd. Vs. CIT, 284 ITR 434 (SC) which also relates to the levy
of interest ... justified whereas the Karnataka High Court in the case of Kwality
Biscuits Ltd. 243 ITR 519 has expressed a contrary view. Appeal filed
Supreme Court, the Apex Court decision in Kwality Biscuits
was holding the field. In view of the said decision, no advance tax was
payable under ... decision of
Hon'ble Apex Court in the case of Kwality Biscuits Ltd. rendered on
26/04/2006. No advance tax was payable
Supreme Court in the case of Kwality
Biscuits Ltd. V CIT, 284 ITR 434(S.C) to support his
contention that where income has been ... Supreme Court in the case of
Kwality Biscuits Ltd. (supra) is in context of Section 115J of
the Act, which is different than Section 115JB
Corpn. Ltd.
"This view of the Karnataka High Court in Kwality Biscuits
Ltd. was not shared by the Gauhati High Court in Assam
Bengal ... noted that the judgment of the Karnataka
High Court in Kwality Biscuits Ltd. was confined to Section
115J of the Act. The order
Supreme
Court in the case of Kwality Biscuits Ltd. 284 ITR 434 (SC).
The learned A.R. further submitted that the former ... wrongly relied on the decision
of CIT vs. Kwality Biscuits Ltd. 284 ITR 434 (SC) which has
been overruled in the case of JCIT
decision of the Karnakata High Court in the case of Kwality Biscuits Ltd.(284 ITR 434)
3.1 The ld CIT(A) noticed that ... distinguished the facts of the present case from the case of Kwality Biscuits Ltd. The CIT(A) noted that the AO has placed reliance