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The Appellate Tribunal addressed the issue of levying interest u/s 234B in proceedings u/s 147/148. The AO had enhanced the interest from the date of the original assessment order u/s 143(3) to the date of the order u/s 147. However, as the original demand was already paid and there was no discussion on enhancing interest in the reassessment order, the Tribunal held that interest u/s 234B was not applicable. The CIT(A) misunderstood the issue, stating interest u/s 234B is automatic, but the Tribunal disagreed. Since the demand was paid and no income variation occurred, interest u/s 234B was deemed unnecessary. The Tribunal allowed the assessee's appeal, deleting the interest charged by the AO.
The Appellate Tribunal addressed the issue of levying interest u/s 234B in proceedings u/s 147/148. The AO had enhanced the interest from the date of the original assessment order u/s 143(3) to the date of the order u/s 147. However, as the original demand was already paid and there was no discussion on enhancing interest in the reassessment order, the Tribunal held that interest u/s 234B was not applicable. The CIT(A) misunderstood the issue, stating interest u/s 234B is automatic, but the Tribunal disagreed. Since the demand was paid and no income variation occurred, interest u/s 234B was deemed unnecessary. The Tribunal allowed the assessee's appeal, deleting the interest charged by the AO.
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