https://www.taxtmi.com/caselaws?id=38293 The court dismissed all challenges to the notice under section 221 of the Income-tax Act, 1961. It ruled that the notice was valid, allowing the petitioner to contest the recoverability of interest claimed. The court held that interest could not be charged for the assessment year under the 1922 Act, leading to the conclusion that penalty for non-payment of interest was not applicable. Additionally, the court determined that penalty imposition was not time-barred and that the principle of res judicata did not apply in this case. The Income-tax Officer was directed to reconsider the interest issue before proceeding further. en-us Thu, 04 Mar 1976 00:00:00 +0530 Mon, 05 Apr 2010 13:23:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38293 The court dismissed all challenges to the notice under section 221 of the Income-tax Act, 1961. It ruled that the notice was valid, allowing the petitioner to contest the recoverability of interest claimed. The court held that interest could not be charged for the assessment year under the 1922 Act, leading to the conclusion that penalty for non-payment of interest was not applicable. Additionally, the court determined that penalty imposition was not time-barred and that the principle of res judicata did not apply in this case. The Income-tax Officer was directed to reconsider the interest issue before proceeding further. Case-Laws Income Tax Thu, 04 Mar 1976 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38293