1978 (12) TMI 107

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....on. He also disallowed the claim of bad debt of Rs. 250 in the name of A. Arumugam on the ground that the assessee has not taken any steps to recover the same from the debtor. For the same reasons he disallowed another claim of bad debt of Rs. 880 in the name of Karuppiah Pillai of Salyuamangalam. The ITO also charged interest of Rs. 356 under s. 139 (8) and Rs. 560 under s. 217(A). The ITO also disallowed a sum of Rs. 28 claimed as new account expenses in H.O, a sum of Rs. 373 claimed as debit under Budalur Branch, new account expenses of Rs. 28 under Budalur Branch and donation of Rs. 179 but these disallowances were not agitated in appeal before the AAC. Another disallowance of Rs. 615 relating to tea to customers was deleted by the AAC ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....y interest on the ground that he was not liable to pay advance tax at all or that the amount of advance tax determined by the ITO as payable ought to be reduced or that the return was not belated or that the penal position was not attracted at all and his objection relates merely to the question of waiver or reduction of interest, such objection does not amount to denial of liability to pay interest and, therefore, the assessee has no right of appeal, this point cannot be agitated upon. In the light of the above submission of the assessee's counsel and in view of the clear submission made by the assessee's counsel that he was not questioning the liability to pay advance tax or the liability to pay interest, we are of the view that this poin....