1986 (8) TMI 9

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....tions, the challenge is against the order passed by the Commissioner of Income-tax under section 264 of the Income-tax Act, 1961, for the years 1978-79 and 1979-80. It is exhibit P-4 in O.P. No. 1550 of 1981 dated February 4, 1981. Interest was levied for the above two years by the Income-tax Officer under section 139(8) of the Income-tax Act and also under section 215 of the Act. It is common gro....

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....or reduction of interest levied under sections 139(8) and 215 of the Act. In such Circumstances, in the light of the decision of the Supreme Court in Central Provinces Manganese Ore Co. Ltd. v. CIT [1986] 160 ITR 961, it is not proper for this court to examine the legality or validity of the order passed by the Commissioner of Income-tax dated February 4, 1981, for the above two years. All the sam....