1998 (8) TMI 48

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....pellate Tribunal at the instance of the Revenue referred the following questions relating to the assessment year 1982-83 for the opinion of this court : "(1) Whether, on the facts and in the circumstances of the case, the Tribunal was right in law and in fact in holding that the interest was not leviable under section 217(1) of the Income-tax Act, 1961 ? (2) Whether, on the facts and in the ....

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....ribunal has not considered the ambit and scope of section 209A inserted by the Finance Act, 1978, with effect from June 1, 1978, which is germane for the assessment years in question. The submission of senior standing counsel is that before reaching the conclusion that the assessee was not liable to pay any advance tax or to file an estimate of the advance tax, the Appellate Tribunal has not given....