1993 (2) TMI 151

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....e framed afresh. The first appeal filed by the assessee is against that order. 4. Although the learned counsel for the assessee has given very vehement arguments in support of his case, we are of the opinion that firstly because the assessment on the basis of the order under s. 263 has already been framed and the assessee has come in appeal before us in ITA No. 1367/Jp/1989 on the basis of that....

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....r. 1985-86 was justified. The learned counsel has drawn our attention to the fact that in assessee's own case for the asst. yrs. 1981-82 to 1984-85 interest @ 24% had been allowed by the Revenue itself and that it is at that rate that the assessee has been paying as well as receiving interest. In these circumstances, the addition made by the Assessing Officer by holding that interest payment @ 15%....