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2018 (8) TMI 982 - ITAT DELHICharging of interest u/s 220(2) - demand was raised first time - additions made in the rectification order passed u/s 154 - assessee contended that such an interest can be charged only if the assessee has defaulted in payment of demand as per notice of demand issued u/s 156 - Held that:- A demand in respect of such amount could be raised only after passing the rectification order and it is the default, if any, in payment of such demand that would attract the interest under section 220 (2) of the Act. It is, therefore, simple and plain that the rectification order itself cannot include the interest under section 220 (2) of the Act, and the tax determined in the rectification order does not relate back to the assessment order - Demand of interest is not valid - Decided against the revenue.
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