1996 (4) TMI 87

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....g two questions have been referred for our opinion : " 1. Whether, on the facts and in the circumstances of the case, the Tribunal was legally correct in holding that the provisions of section 139(8) of the Act have no application to reassessment proceedings ? 2. Whether, on the facts and in the circumstances of the case, the Tribunal was legally correct that the matter was highly debatable ....

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....ment's appeal to the Tribunal failed. Hence, this reference. The short question before us is whether interest under section 139(8) can be charged in proceedings under section 148 for reassessment, This point is covered by a decision of a Division Bench of the Karnataka High Court in the case of Charles D'Souza v. CIT [1984] 147 ITR 694, as well as a decision of the Rajasthan High Court--Jaipur ....