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2002 (10) TMI 37 - HC - Income TaxDeduction and payment of income-tax at source in time in terms of section 194C - assessee made the payment on March 13, 1990, obviously with substantial delay. The Assessing Officer demanded interest amounting to Rs. 28,834 under section 201(1A) of the Income-tax Act. There is no dispute on the amount of interest computed under section 201(1A), if the assessee is otherwise liable. The only contention raised against the demand of penal interest is the limitation provided under section 231 of the Income-tax Act which stands deleted by the Direct Tax Laws (Amendment) Act of 1987, with effect from April 1, 1989. - The limitation under section 231 so far as the interest is concerned applies only with reference to the date of demand. Since the date of demand itself is taken as the proceedings for recovery, the question of limitation does not apply at all in this case. Therefore, the assessee cannot contend that the assessee was an "assessee in default" and the limitation for recovery of interest has to be reckoned from the commencement of the financial year.
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