TMI Blog1981 (8) TMI 62X X X X Extracts X X X X X X X X Extracts X X X X ..... Bombay, and to award appropriate interest to the petitioner under s. 214 of the I.T. Act, 1961 (hereinafter referred to as " the Act "). Only few facts are required to be stated to appreciate the grievance of the petitioner. The petitioner was liable for payment of advance tax for the first time in the assessment year 1972-73. Accordingly, the petitioner filed the estimate of income on December ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ply from the ITO, a letter dated May 14, 1975, was addressed to the Commissioner of Income-tax, Bombay City. The Commissioner, by his order dated September 17, 1975, passed in exercise of the powers under s. 264 of the Act, directed the ITO to allow appropriate interest under s. 214 of the Act. The grievance of the petitioner is that in spite of this order the ITO has failed to grant appropriate i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ral Govt., the ITO is not passing the order. It is obvious that the circulars issued by the Government have no force of law, and in any event the circular which came subsequent to the order of the Commissioner has no application to the facts of the present case. The ITO is bound to pass appropriate orders awarding interest to the petitioner under s. 214 of the Act. Accordingly, respondents Nos. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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