2022 (5) TMI 447

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....i Love Kumar, Sr. DR ORDER PER PAVAN KUMAR GADALE JM: This appeal is filed by the assessee against the order of the National Faceless Appeal Centre, (NFSC), Delhi passed u/s 271(1)(c) and 250 of the Act. The assessee has raised the following grounds of appeal: Principal of Natural Justice Violated: 1. The id CIT(A) erred in passing the impugned order dated 20/09/2021 exp....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....54 dated 4/2/2020 , therefore levy of interest up to the date of passing order u/s. 154 of the Act is bad in law. 2. The AO erred in charging interest u/s. 234B of the Act from 1st day of A. Y till passing the order u/s 154 dated 14.02.2020 on the total amount determined without taking into consideration the payments made in the intervening period. 3. The assessee craves leave to....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... passed on 14.02.2020, where the total income was revised to Rs. 4,81,09,193/-. 3. Aggrieved by the rectification petition the assessee has filed an appeal before the CIT(A). Whereas the CIT(A) has dismissed the appeal of and confirmed the calculations made u/s 234B of the. Aggrieved by the order the assessee has filed an appeal before the Hon'ble Tribunal. 4. At the time of hearing the Ld. ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... in charging interest from first day of assessment year which the passing of rectification order u/s 154 and the ld. AR also substantiated with the chart referring the dates on which the payments have been made and further submitted that an opportunity to provide for substantiate before the lower authorities, the Ld. DR has no specific objection. Considering the overall facts, circumstances and de....