Litigation - two different stands

[chaganti srinivas]

For 2 different audits points, we wish to pay interest amount due to small amounts, where as in other case, due to interest amounts are high decided to contest. How dept. can litigate our two different stands in similar case?

[Guest]

Once you decide to contest for one point, what is the hard to contest for all the points since the litigation would be one? However, If you deposit interest amount on 2 different points due to small amount and would contest on 3rd point, department is nothing to do. The point to law is to be decided on merits without taking into the statd of the assessee.

AI Summary

Party Considers Paying Interest on Two Audit Points, Contests Third Due to High Interest; Department Can't Interfere. A party is considering paying interest on small amounts identified in two audit points but intends to contest a third point due to a higher interest amount. They question how the department might view their differing approaches in similar cases. The response suggests that if they choose to contest one point, they could contest all since the litigation would be unified. However, if they pay interest on two points and contest the third, the department cannot interfere, as the decision should be based on legal merits, not the taxpayer's stance.