1982 (7) TMI 216

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.... is a registered firm. Against the assessment order the assessee went up in appeal before the AAC and the grounds raised before the AAC were firstly against the disallowance under the head 'travelling expenses' and secondly against the charge of interest under s. 139(8). The AAC, while deleting the disallowance out of travelling expenses, refused to entertain the ground objecting to the charge of ....

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....ich were considered in the latest ruling of the Hon'ble High Court of Delhi. 4. On the other hand, the ld. Deptl. Rep. Shri Sharma, relying on the ruling of the Hon'ble High Court of Allahabad in the case of CIT vs. Geeta Ram Kali Ram (1980) 15 CTR (All) 67 : (1980) 121 708 (All) submitted to us that even if an appeal was filed on other grounds, it was not open to the assessee in the appeal to ....

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....idering the earlier rulings on this issue, including the ruling of the Hon'ble High Court of Allahabad cited by the ld. Deptl. Rep. We, therefore, hold that while no appeal lies against the charge of interest alone, it is open to an assessee in an appeal filed on other grounds as well to object to the charge of interest also in the appeal filed. Viewed in this context, it is not under dispute that....