1995 (3) TMI 57

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.... J.--On the request of the Revenue the Income-tax Appellate Tribunal has referred the following question of law arising out of its order dated September 3, 1984, in respect of the assessment year 1972-73 : " Whether, on the facts and in the circumstances of the case, the Appellate Tribunal was justified in not upholding the interest charged by the Income-tax Officer under sections 139(8) and 21....

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....erest and since the income was to be determined in accordance with the order of the Appellate Assistant Commissioner, it was directed that recalculation be made accordingly. In the second appeal before the Income-tax Appellate Tribunal, it was observed that the assessment under section 147 is not a regular assessment and, therefore, interest under sections 217 and 139(8) cannot be charged. It was ....