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2019 (1) TMI 203 - AT - Income TaxCharging of interest u/s 234B for non payment of advance tax - assessment framed u/s 147 - additions made towards unexplained investment in partnership firm - Held that:- No taxes had been paid initially by the assessee and the addition made u/s 147 of the Act was on account of unexplained investment made by the assessee in partnership firm. The said addition cannot be said to be on account of an issue on which there existed a bonafide dispute. The assessee therefore was liable to include the same while estimating his income for payment of advance tax and having not done so the assessee had defaulted initially in the payment of advance tax and was thus liable to pay interest when the said amount was added to his income in reassessment proceedings as per section 234B(3) of the Act. - decided against assessee
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