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2022 (3) TMI 378 - AT - Income TaxEntitlement of interest on the belated payment of interest as per section 244A - HELD THAT:- We find that, there is no dispute that the Assessee was due and entitled for grant of interest for the period 01/04/2003 to 24/03/2003 (36 months), which has been directed to be granted to the Assessee by this Tribunal [2018 (1) TMI 86 - ITAT DELHI] In compliance with the above direction of the Tribunal, the AO has granted interest w.e.f 01/04/2003 to 24/03/2006 to the assessee on 04- 05-2018 u/s. 244A at the rate of 6% p.a - AO has fully complied with directions of the Tribunal issued and there was no direction to compute interest on the interest or to pay compensation on account of belated payment of the interest as claimed by the Assessee in the present Appeal. AO had complied with the direction of the Tribunal in toto, therefore we cannot find fault with the Order passed by the AO. Tribunal vide Order [2019 (11) TMI 86 - ITAT DELHI] specifically directed AO to compute the interest on late payment of the interest, but in the Order dated 29-12-2017 [2018 (1) TMI 86 - ITAT DELHI] the Tribunal has directed the AO to “grant interest to the Assessee under Section 244A of the Income Tax Act w.e.f. 01/04/2003 to 24/03/2006”. There was no direction to pay either interest on interest or to pay composition for late payment of interest and the said Order of the Tribunal reached finality. Therefore the Order of the Tribunal in Assessee’s own case [2018 (1) TMI 86 - ITAT DELHI] is not applicable to the facts and circumstances of the present Appeal. - Decided against assessee
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