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2011 (9) TMI 10

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....erters Pvt. Ltd. has filed the present writ petition for quashing of notices dated 23rd December, 2005 and 8th December, 2006 issued by the Income Tax Officer, Ward-3(2), New Delhi and the rectification order dated 25th January, 2007, which was also passed by the same officer. 2. The petitioner contends that the respondents cannot levy interest under Section 220(2) of the Income Tax Act, 1961 (fo....

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....itions attained finality. 4. Penalty under Section 271(1)(c) of Rs. 2,59,240/- and Rs. 2,96,643/-for assessment years 1994-95 and 1995-96 were imposed and were sustained in the first appeal. The petitioner did not file any further appeal and the orders imposing penalty have attained finality. The petitioner had filed an application under Section 273A of the Act for waiver of penalty, which was di....

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.... (SC). 6. The respondent, on the other hand, has submitted that the said decision will only apply in case demand had been paid in full at the initial stage. However, when demand has not been paid in full, in view of Section 3 of the Taxation Law (Continuation and Validation of Recovery Proceedings) Act, 1964, the earlier notice under Section 156 of the Act stands revived. In this connection, they....

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...., 2006 are concerned, these are show cause notices, which have been issued to show cause why penalty under Section 221(1) of the Act for failure to deposit the tax should not be imposed. As these notices are/were show cause notices, we do not see any reason to interfere at this stage. However, as far as the order dated 25th January, 2007 is concerned, the said order was passed under Section 154/25....