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2024 (1) TMI 419 - ITAT CHENNAIRectification u/s 154 charging interest u/s 234A, 234B & 234C - rectification on debatable issue - HELD THAT:- We noted that now assessee filed a copy of one Tribunal judgment in the case of Ms. Priti Pithawala [2003 (3) TMI 743 - ITAT MUMBAI] wherein the chargeability of interest u/s. 234A in case of return filed u/s. 147 r.w.s. 148 of the Act was under dispute. This is one of the view of the Tribunal. Even in the case of CIT vs. Salora International Limited [2010 (5) TMI 67 - HIGH COURT OF DELHI] held that charging of interest u/s. 234B and 234C of the Act by the ld. AO, as a consequence of the order passed u/s. 154 of the Act, was a debatable issue which a AO could not do by invoking the provisions of Sec. 154 of the Act. Hence, while acting u/s. 154 of the Act, interest u/s. 234A of the Act in the present case cannot be charged. Hence, this jurisdictional issue of the assessee’s cross objection is allowed,
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