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2011 (2) TMI 45 - ITAT CHENNAISearch and seizure - notices under section 154, on the assessees wherein it was proposed to levy interest under sections 234A, 234B and 234C of the Act on the ground that it was a mistake apparent from the record - method of computation of the interest is specifically provided in the sections 234A(3) and 234B(3) in the case of assessments under section 153A and section 234C - non-application of a specific provision being mistake apparent from record - Assessing Officer was invoked the provisions of section 154 for rectifying the mistake of the non-levy of interest under sections 234A, 234B and 234C of the Act in the original assessment – Assessing Officer was right in invoking the provisions of section 154 for rectifying the mistake of the non-levy of interest under sections 234A, 234B and 234C of the Act in the original assessment. The computation of the interest under section 234A is to be done for every month or part of the month comprised in the period commencing on the day immediately following the expiry of the time allowed in the notice under section 153A. The interest under section 234B is to be computed on the amount by which the tax on the total income determined on the basis of the assessment under section 153A exceeds the tax on the total income determined under sub-section (1) of section 143 on the return filed in response to the notice issued under section 153A. In regard to the levy of interest under section 234C, there is no provision similar to section 234A(3) or section 234B(3) in the said section.
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