https://www.taxtmi.com/caselaws?id=5932 SC held that interest levied under s.139(8) and s.215 is part of the assessment process and not appealable under s.246. The Court affirmed the Commissioner's orders rejecting revision petitions, but on different grounds, noting that absent any prior application to the ITO for reduction or waiver under s.139(8)/s.215 and Rule 117A, there was no denial for the Commissioner to review. The assessee remains free to apply to the ITO for reduction or waiver of the interest under the statutory provision and rules. en-us Sat, 17 May 1986 00:00:00 +0530 Thu, 30 Oct 2025 12:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5932 SC held that interest levied under s.139(8) and s.215 is part of the assessment process and not appealable under s.246. The Court affirmed the Commissioner's orders rejecting revision petitions, but on different grounds, noting that absent any prior application to the ITO for reduction or waiver under s.139(8)/s.215 and Rule 117A, there was no denial for the Commissioner to review. The assessee remains free to apply to the ITO for reduction or waiver of the interest under the statutory provision and rules. Case-Laws Income Tax Sat, 17 May 1986 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5932