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2014 (7) TMI 685 - AT - Income TaxChargeability of Interest u/s 234B(1) or 234B(3) - Wrong charging of interest – Held that:- CIT(A) righty of the view that the intimation u/s 143(1)(a) is not an assessment and if the assessment for the first time is completed u/s 147 then the case will fall under sub-section (1) of section 234B - assessment for the first time was completed under the provisions of section 147 therefore, the case will fall under the provisions of sub-section (1) of section 234B - going by the Explanation 2 to Section 234B, when the assessment was made for the first time u/s 147 r.w section 143(3), the assessment is a regular assessment attracting the provisions of sub-section (1) of Section 234B - assessment is a regular assessment and not a reassessment – thus, the order of the CIT(A) is upheld – Decided against Assessee.
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