1992 (11) TMI 82

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....tax Department, the following question of law has been referred to this court in respect of the assessment year 1971-72 : " Whether, on the facts and in the circumstances of the case, the Tribunal is correct in holding that the order of the Income-tax Officer granting interest to the assessee under section 214 cannot be rectified under section 154 ? " Briefly stated, the facts are that the a....

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....ection 154. The appeal of the assessee was allowed. The Department then filed a second appeal before the Tribunal who also came to the same conclusion, namely, that whether the payments made by the assessee were advance tax or not on which interest under section 214 to be paid was a debatable issue and, in view of various decisions, both for and against the proposition, action could not be taken u....