https://www.taxtmi.com/caselaws?id=59787 An assessee may maintain an appeal where the challenge is not merely to the quantum of interest but to the very liability to interest under the charging provision. The Tribunal applied the principle that a complete denial of liability makes the levy justiciable in appeal, and remitted the matter because the factual basis for the levy had not been examined by the first appellate authority. The issue was restored to the Commissioner (Appeals) for fresh decision on merits. en-us Wed, 11 Jun 1980 00:00:00 +0530 Sat, 01 Jan 2011 12:01:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59787 An assessee may maintain an appeal where the challenge is not merely to the quantum of interest but to the very liability to interest under the charging provision. The Tribunal applied the principle that a complete denial of liability makes the levy justiciable in appeal, and remitted the matter because the factual basis for the levy had not been examined by the first appellate authority. The issue was restored to the Commissioner (Appeals) for fresh decision on merits. Case-Laws Income Tax Wed, 11 Jun 1980 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59787