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1988 (11) TMI 37

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..... , Saraswati Industrial Syndicate Limited, is a limited company and its business is manufacture of machinery for sugar mills and cement factories and to execute casting fabrication and other jobs for such industrial concerns, besides manufacture of sugar. The matters raised here pertain to the assessment year 1974-75. The two questions to be answered by this court are : " 1. Whether, on the fac .....

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..... on regarding interest, reference may be made to the judgment of the Supreme Court in Central Provinces Manganese Ore Co. Ltd. v. CIT [1986] 160 ITR 961, where it was held that the levy of interest was a part of the process of assessment and it was open, therefore, to an assessee to dispute the levy of interest in appeal, provided he limited himself to the ground that he is not liable to the levy a .....

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