1986 (8) TMI 9

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..... of Income-tax under section 264 of the Income-tax Act, 1961, for the years 1978-79 and 1979-80. It is exhibit P-4 in O.P. No. 1550 of 1981 dated February 4, 1981. Interest was levied for the above two years by the Income-tax Officer under section 139(8) of the Income-tax Act and also under section 215 of the Act. It is common ground that the interest levied under section 139 of the Act can be wai .....

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..... Act. In such Circumstances, in the light of the decision of the Supreme Court in Central Provinces Manganese Ore Co. Ltd. v. CIT [1986] 160 ITR 961, it is not proper for this court to examine the legality or validity of the order passed by the Commissioner of Income-tax dated February 4, 1981, for the above two years. All the same, we are of the view that the assessee should be given a chance to v .....

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