2004 (8) TMI 18

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ance of the assessee, the Income-tax Appellate Tribunal, Amritsar Bench, Amritsar (for short "the Tribunal"), has referred the following questions of law arising out of its order dated March 18,1994 for the assessment year 1978-79, for the opinion of this court: "1. Whether the Income-tax Appellate Tribunal was correct in law in upholding the action of the Income-tax Officer in initiating proceed....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....of the Income-tax Act, 1961 (for short "the Act"). However, while filing the return for the said year, this income was not included in the computation of income but the following footnote was given: "Please also consider the interest paid under section 244(1A) by the Income-tax Department during the year from February 1, 1977 to January 31, 1978, as no interest intimation has been given to the as....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....nation did not find favour with the Assessing Officer who passed the order under section 154 of the Act and added the interest received by the assessee to its total income. This action was upheld by the Commissioner of Income-tax (Appeals) as well as the Tribunal as it was held that in view of the footnote given by the assessee itself, it was merely a case of oversight on the part of the Assessing....