TMI Blog2014 (10) TMI 585X X X X Extracts X X X X X X X X Extracts X X X X ..... the revenue by relying upon Commissioner of Income-tax Versus Ashok Kumar [2010 (9) TMI 771 - Punjab and Haryana High Court] – the assessee is entitled to adjustment of seized amount towards advance tax liability from the date of making the application in that regard - The Tribunal has rightly held that the assessee was entitled to adjustment of the amount and no interest could be charged on that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r, order dated 12.03.2013 (Annexure A-IV) passed by the Commissioner of Income Tax (Appeals-I), Ludhiana, as well as order dated 20.09.2013 (Annexure A-V), passed by the Income Tax Appellate Tribunal Chandigarh Bench 'B', Chandigarh on the following substantial questions of law:- 1. Whether, on the facts and in the circumstances of the case, Hon'ble ITAT is justified in law in obse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Counsel for the revenue submits that the only question that the revenue presses is chargeability of interest under Section 234B and 234C of the Income Tax Act, 1961, i.e., question no.3. Counsel for the revenue submits that though the Tribunal has answered this question against the revenue by placing reliance upon a judgment of this Court in Income Tax Appeal No.36 of 2004 (Commissioner of Inco ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... not referred to as a ground of appeal much less has it been framed as a substantial question of law. In view of what has been recorded hereinabove, question no.3 having already been answered against the revenue in Income Tax Appeal No.36 of 2004 (Commissioner of Income Tax v. Ashok Kumar, (2011) 334 ITR 355 (P H), the appeal lacks merit and is, therefore, dismissed. - - TaxTMI - TMITax - ..... X X X X Extracts X X X X X X X X Extracts X X X X
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