https://www.taxtmi.com/caselaws?id=37745 An assessee can maintain an appeal against levy of interest under sections 215 and 217 where the challenge goes to the root of liability to be assessed, not where it is confined to mere quantification of interest; on the facts, the appellate ground was linked to the underlying assessment, so the appeal was competent. A discretionary power to reduce or waive interest under the relevant rules must be shown on the record to have been considered and exercised, and a presumption of regularity is insufficient where no such consideration appears. On the material before the Court, no exercise of discretion was shown. en-us Fri, 27 Jan 1978 00:00:00 +0530 Wed, 31 Mar 2010 17:26:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=37745 An assessee can maintain an appeal against levy of interest under sections 215 and 217 where the challenge goes to the root of liability to be assessed, not where it is confined to mere quantification of interest; on the facts, the appellate ground was linked to the underlying assessment, so the appeal was competent. A discretionary power to reduce or waive interest under the relevant rules must be shown on the record to have been considered and exercised, and a presumption of regularity is insufficient where no such consideration appears. On the material before the Court, no exercise of discretion was shown. Case-Laws Income Tax Fri, 27 Jan 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=37745