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2011 (7) TMI 135 - KARNATAKA HIGH COURTLevey of interest u/s 234B - Reassessment u/s 147 - Since, there was a determination of tax u/s (1)(a) and return filed by the assessee declaring his income as Rs. 30,590 was accepted by the Department by its order dated 24-6-1991 - It is thereafter, proceedings were initiated u/s 147 of the Act - In pursuance of the notice issued, revised return was filed on 30-12-1993 declaring the income of Rs. 1,50,590 - It is on that return, the order came to be passed u/s 143(3) on 28-1-1994, Therefore, it is not a case of assessment made for the first time - It is a case of order of reassessment or recomputation u/s 147 - Therefore, the interest is to be calculated from 24-6-1991, the date on which determination of tax was made u/s (1)(a) of the Act - To that extent, the order passed by the authorities is illegal and requires to be set aside - Decided in favour of assessee.
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