1991 (2) TMI 69

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.... by T. D. SUGLA J. -The Tribunal has referred to this court the following three questions as questions of law under section 256(1) of the Incometax Act, 1961 : " 1. Whether, on the facts and in the circumstances of the case, the Tribunal erred in law in holding that there was a mistake apparent from the records within the meaning of section 154, in so far as the allowance of interest of Rs. ....

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....the purpose of considering whether or not the assessee had discharged its obligation. The Gujarat High Court in the case of Chandrakant Damodardas v. ITO [1980] 123 ITR 748, and our High Court in the case of Pfizer Limited v. K. N. Anantharama Aiyar, CIT [1987] 163 ITR 461, have held that such payment is required to be considered as a payment towards advance tax within the meaning of section 210. ....