2017 (4) TMI 46

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....2014 - 15 dated 29/08/2016 and ITA No.594 /BGM/2014 - 15 dated 29/08/2016 for the assessment years 2011 - 12, 2012 - 13, 2013 - 14 and 2014 - 15 respectively. ITA No.207 & 208/PAN/2016 for the assessment years 2011 - 12 & 2012 - 13 are against the confirmation of the levy of interest under Section 201(1A) and ITA No. 209 & 210/PAN/2016 for the assessment years 2013 - 14 and 2014 - 15 are against the confirmation of the levy under Section 201(1) of the Act.. ITA No.211/PAN/2016 to ITA.NO.215/PAN/2016 are appeals filed by the M/s State Bank of Mysore, Hindwadi Branch against the orders of the Learned.CIT(A) in appeal No ITA No.560/BGM/2014 - 15 dated 29/08/2016, ITA No.561/BGM/2014 - 15 dated 29/08/2016, ITA No.567/BGM/2014 - 15 dated 29/08/2....

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....he assessment year 2016 -17 VTU applied for registration under Section 12AA of the Act and the same was granted the registration as a Charitable Trust / Society. Consequently VTU had filed an application under Section 119(2)(b) of the Act to the CBDT praying for retrospective recognition of the registration under Section 12AA of the Act. VTU had been granted the registration under Section 12AA and 80G vide order dated 08.12.2015. The application before the CBDT is pending till date. 4. It was submitted that consequent to VTU being denied the exemption under Section 10(23C) of the Act, the Assessee's were held liable under Section 201 and 201(A) of the Act on account of the non deduction of TDS under Section 194A (3) in respect of the int....

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....t of the levy under Section 201(1) of the Act. It was further submitted that in respect of the levy of interest Under Section 201(1A) the interest is compensatory in nature as has been held by the Hon'ble Supreme Court in the case of Hindustan Coca Cola Beverage (P) Ltd. refer to (supra). It was submitted that the bonafide belief could not remove the liability for payment of interest under Section 201(1A) of the Act. In regard to the quantification of levy of interest under Section 201(1A) the issue could be restored to the file of the Assessing Officer to re-adjudicate the issue after considering the fact with form 26A. 6. In reply Learned Authorized Representative of the assessee submitted that he had no objection in restoring the issu....