1982 (2) TMI 30

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....or the assessment year 1970-71, the ITO made an assessment on Poyakkaraveettil Hamsa consequent upon a seizure of Rs. 84,000 by the Enforcement Directorate during a raid conducted at his premises. The amount seized was claimed by the petitioner as his. As a result of this claim, an alternative or protective assessment was made upon the petitioner, Abdul Kareem Hajee, in respect of the amounts seiz....

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....by the ITO as seen in ex. P-6, which reads : "The interest chargeable u/s. 220(2) for the assessment year 1970-71,on Rs. 60,278 works out to Rs. 24,682. This is charged. This should be paid as per demand notice. " Exhibit P-6 was affirmed in revision by the Commissioner by ex. P-7 dated March 4, 1978. It is contended by the petitioner's counsel, Shri Paripoornan, that in so far as ex. P-2A w....

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....oration. The finality of ex. P-2A was qualified by and subject to appeal, which was taken before the appellate authority. The order of the appellate authority itself was likewise provisional during the period allowed for filing an appeal or during the pendency of the appeal. When the order of the AAC concerning the petitioner was finally set aside by the Tribunal, thereby affirming ex. P-2A order ....