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2016 (4) TMI 712

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..... n 127 of the Act transferring jurisdiction from one Officer to the another - Held that:- The facts which are not in dispute are that notice under section 158BC of the Income Tax Act was issued on 24.12.2002 which was received by assessees on 04.01.2003. However, the assessees filed their return on 16.07.2004. The assessing officer calculated interest for the period starting from December, 2002 til .....

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..... involved in both these appeals, they are being heard together and are being disposed of by this common judgement. The assessees are in appeal under section 260A of the Income Tax Act arising out of orders passed by the Income Tax Appellate Tribunal, Patna Bench, Patna (for short the Tribunal) on 27.07.2007 and 12.02.2007 in respect of Income Tax (SS) Appeal No. 83/Pat/06 and Income Tax (SS) Ap .....

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..... ulated interest for the period starting from December, 2002 till the date of filing of the return. The argument of the appellants is that order under Section 127 of the Income Tax Act was served on 11.09.2003 and 09.09.2003 and, therefore, the charge of interest should commence from date of service of such notice. It is not disputed that the notice dated 23/ 24.12.2002 was issued by the tran .....

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