1990 (11) TMI 68

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.... S. PARIPOORNAN J. -The petitioner in Original Petition No. 4994 of 1990, a public limited company, is the appellant in this writ appeal. In the original petition, the prayer was to quash exhibit P-9 order passed in revision by the second respondent-Commissioner of Income-tax, dated November 17, 1988. The appellant is an assessee to income-tax. For the assessment year 1971-72, the appellant filed ....

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....nsports [1985] 155 ITR 548, construed the words "regular assessment" occurring in section 214(1) of the Income-tax Act as the initial assessment or the first assessment made by the Income-tax Officer under section 143(3) or under section 144 of the Act and held that it does not include any modified or revised order passed by the Income-tax Officer subsequently to give effect to any appellate order....

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...." up to which the Revenue is bound to pay interest for the advance tax paid during the financial year. There is a short cleavage of judicial opinion on this point. The Calcutta, Gujarat and Rajasthan High Courts, in the decisions in Chloride v. CIT [1977] 106 ITR 38 (Cal) ; General Fibre Dealers Ltd. v. ITO [1979] 116 ITR 40 (Cal) ; Bardolia Textile Mill v. ITO [1985] 151 ITR 389 (Guj) [FB] and CI....