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2005 (10) TMI 47 - GUJARAT HIGH COURTInterest levied under section 215 - In fact, nothing has been brought on record to rebut the findings recorded by the Commissioner (Appeals) and the Tribunal, namely, the assessee could not have anticipated the upward revision in income, and that too, for earlier assessment years, which was finalized only in March, 1986. The Revenue has not even pleaded, much less established, that the assessee had the knowledge and could have anticipated at the time when it filed its estimate of advance tax payable by it. - Held that Tribunal is right in law and on facts in deleting the interest levied under section 215 of the Income-tax Act amounting to Rs. 1,56,970
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