https://www.taxtmi.com/caselaws?id=57268 Interest under sections 139(8) and 215/217 was held not leviable where the assessee filed the return as an AOP only after the Supreme Court clarified the legal position and after notice under section 148 was issued. The Tribunal accepted that sufficient cause prevented timely filing of the return and advance-tax estimate, that the delay was not deliberate, and that no proper opportunity had been given before charging interest. It also recognised that the assessee could dispute the levy in appeal when liability itself was denied. On these facts, the interest charge was found unsustainable and was deleted. en-us Thu, 29 Nov 2001 00:00:00 +0530 Thu, 09 Dec 2010 12:18:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=57268 Interest under sections 139(8) and 215/217 was held not leviable where the assessee filed the return as an AOP only after the Supreme Court clarified the legal position and after notice under section 148 was issued. The Tribunal accepted that sufficient cause prevented timely filing of the return and advance-tax estimate, that the delay was not deliberate, and that no proper opportunity had been given before charging interest. It also recognised that the assessee could dispute the levy in appeal when liability itself was denied. On these facts, the interest charge was found unsustainable and was deleted. Case-Laws Income Tax Thu, 29 Nov 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=57268