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1981 (6) TMI 57 - ITAT COCHINExtract: .......en this contention only on record and has come to a finding that the levy of interest was not valid because there was no finding by the ITO as required under section 216. We agree with the Commissioner (Appeals) that in the absence of such a finding, the ITO cannot proceed to levy interest under section 216. 10. The appeal is, therefore, dismissed.
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