2015 (10) TMI 1411

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ident).- These two appeals, filed by the Revenue, are directed against the identical but separate orders passed by the Commissioner of Income-tax (Appeals)-21, Mumbai. 2. Admitted facts are that though the assessee determined the self-assessment tax it did not make the payment within the stipulated period and hence notice under section 221 of the Income-tax Act, 1961, was issued by the Assessing....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....to make tax payment. If the taxes are to be paid on the borrowed funds the business would be irretrievably affected and hence the explanation has to be considered in the backdrop of the circumstances of the case. 5. Having regard to the circumstances of the case the learned Commissioner of Income-tax (Appeals) observed that the assessee was having meagre cash and current balances and the assessee....