2021 (10) TMI 267

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....er Dr. B. R. R. Kumar, Accountant Member: The present appeal has been filed by the assessee against the order of ld. CIT (A)-41, New Delhi dated 15.11.2016. 2. Following grounds have been raised by the assessee: "1. That in view of the facts and the circumstances of the case, CIT(A) has erred in upholding the demand of interest of Rs. 16,67,307/- as payable by the Assessee on allege....

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....of the case, CIT(A) has erred in holding that the connotation of 'every month or part thereof appearing in Section 201(1A) mean every calendar month or part thereof, ignoring that it as a 'period of one month' or part thereof. 6. That the ACIT and CIT(A) erred in law and fact in not appreciating that the expression 'month' refers to 'a month reckoned according to the British Calen....

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....so not based on correct legal position." 3. The assessee is a company engaged in the business of EPC and construction infrastructure development and power generation. 4. Order u/s 153 has been issued by the CPC (TDS) charging interest on late payment of the TDS u/s 201(1A). The ld. CIT(A) confirmed the order of the CPC. 5. The relevant undisputed facts of the case are that the assessee de....