1982 (6) TMI 120

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....tertaining and deciding the appeal in regard to charging of interest under s. 139(8) in view of Gauhati High Court's decision in (1976) 103 ITR 505 (Gau) and that "the ld. CIT(A) erred both in facts and in law in holding that amounts paid beyond the date prescribed under s. 211 should still be treated as payments or advance tax and credit for the same should be given in determining interest under ....

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....ty to interest under s. 139(8) of the Act and the same may be deleted." It cannot, therefore, be said that the only ground of appeal for determination before the CIT(A) was the charging of interest under s. 139(8) besides the assessee's denying its liability to interest under s. 139(8) of the Act. The appeal, therefore, against such grounds of appeal clearly lay to the ld. CIT(A) in terms of cl....