Interest under section 139(8) is computed on tax as if a registered firm were assessed as an unregistered firm. Levy of interest under section 139(8) is to be computed on the tax that would have been payable if a registered firm (or an unregistered firm assessed under the special provision) had been assessed as an unregistered firm; Explanation 2 to clause (a) of sub section (8) of section 139(2) mandates use of that hypothetical tax base, so interest is chargeable even where the firm's actual assessment shows total income below the taxable minimum.
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Provisions expressly mentioned in the judgment/order text.
Interest under section 139(8) is computed on tax as if a registered firm were assessed as an unregistered firm.
Levy of interest under section 139(8) is to be computed on the tax that would have been payable if a registered firm (or an unregistered firm assessed under the special provision) had been assessed as an unregistered firm; Explanation 2 to clause (a) of sub section (8) of section 139(2) mandates use of that hypothetical tax base, so interest is chargeable even where the firm's actual assessment shows total income below the taxable minimum.
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