2003 (6) TMI 11

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....3, 234 and 235/Coch. of 1995 in respect of the assessment years 1986-87, 1987-88 and 1988-89 in connection with the orders passed by the Assessing Officer levying interest under section 201(1A) of the Act. I.T.A. Nos. 27, 42 & 50 of 2000 are the appeals filed against the order of the Tribunal on the question arising under section 201(1) of the Act and I.T.A. Nos. 38, 41 & 43 of 2000 are filed against the order of the Tribunal on the question of imposition of interest under section 201(1A) of the Act. The brief facts necessary for consideration of these appeals are as follows: The respondent-assessee is a co-operative bank at Trichur. During the previous years relevant to the assessment years 1986-87 to 1988-89 the respondent assessee had....

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....ggrieved by the order of the first appellate authority both the assessee and the department filed appeals before the Appellate Tribunal. The Tribunal also found that the findings of the first appellate authority that the assessee is in default and that there is a corresponding obligation to pay interest under section 201(1) and section 201(1A) respectively. However, the Tribunal also upheld the view of the first appellate authority that the recovery of the tax and the interest have become barred under section 231 of the Act. The Tribunal for the said purpose relied on the decisions of this court in Traco Cable Co. Ltd. v. CIT [1987] 166 ITR 278 and CIT v. Meat Products of India Ltd. [1997] 224 ITR 1. It is against these orders of the Tribun....