Interest u/s 234A Not Applicable Without Assessment u/ss 143(3), 144, or 147 Due to No Tax Return Filed.

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....Interest u/s 234A(1) or as per Sec. 234A(3) - It has categorically been mentioned in sub-section (3) of Section 234A of the Act that provisions of said sub-section can only be invoked in the case where the completion of assessment U/s 143(3)/144 or 147 of the Act takes place, but admittedly in the present case, no return was filed. There was no occasion for completion of the assessment under the above provisions, therefore, the assesse cannot take benefit of sub-section (3) of Section 234A of the Act. - AT....