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?

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

Differential litigation strategy allows paying minor interest liabilities while contesting major audit issues; legal questions decided on merits.
Taxpayers may deposit interest on minor audit points while contesting other significant points; the department cannot treat the taxpayer's mixed procedural choices as determinative. Each legal issue must be decided on its merits, and paying small liabilities for pragmatic reasons does not bar contesting separate legal grounds arising from the same audit.