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The ITAT adjudicated a tax dispute concerning interest levy under Section 234B, addressing the rectification order passed under Section 154. The tribunal found no sustainable grounds for interest imposition, relying on Supreme Court precedent in Mitsubishi Corporation. The court determined that the Assessing Officer's order lacked merit, as favorable High Court decisions precluded a "mistake apparent from record" under Section 154. Consequently, the tribunal dismissed the revenue's appeal, upholding the principle that interest cannot be levied when established judicial interpretations contradict the original assessment.
The ITAT adjudicated a tax dispute concerning interest levy under Section 234B, addressing the rectification order passed under Section 154. The tribunal found no sustainable grounds for interest imposition, relying on Supreme Court precedent in Mitsubishi Corporation. The court determined that the Assessing Officer's order lacked merit, as favorable High Court decisions precluded a "mistake apparent from record" under Section 154. Consequently, the tribunal dismissed the revenue's appeal, upholding the principle that interest cannot be levied when established judicial interpretations contradict the original assessment.
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