2000 (11) TMI 12

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....ded for in rule 119(3) of the Income-tax Rules, 1962, the interest under section 220(2) of the Income-tax Act, 1961, cannot be taken note of for the purpose of determination of the amount payable by the petitioner under the Kar Vivad Samadhan Scheme. That rule was in force during the assessment years in question namely, 1971-72 to 1973-74. The Kar Vivad Samadhan Scheme provides opportunity to the ....

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....ount of unpaid tax. All that rule 119 provides for is the quantification of the amount which is a mere matter on arithmetic and the specification of the same, in the recovery certificate, to be issued by the Income-tax Officer. The fact that the quantification is done under the Kar Vivad Samadhan Scheme makes no difference so far as the liability of the assessee to pay the interest on the unpaid t....