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2022 (8) TMI 1275

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....f reference, we are referring to ITA No.6418/Del/2016 for Assessment Year 2006-07. 4. The grounds of appeal read as under :- "1. That the order of the Commissioner of Income-tax (Appeals), - Ghaziabad, dated 28.09.2016, the impugned order, is wrong on facts and bad in law; 2. That the Commissioner (Appeals) failed to appreciate that the Assessing Officer erred in holding that the Appellant was liable to deduct tax under Section 194A of the Act on interest of Rs. 29,31,5251- to various depositors. It was an obvious error; 3. That the Commissioner (Appeals) erred in not directing the Assessing Officer to delete the tax of Rs.2,99,016/- charged under Section 194A of the Act on interest of Rs.29,31,525/- to various depositors; 4. That ....

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....bad. 3) The CIT(A), Ghaziabad vide order dated 14.09.2012 in A.No.1338/1339/1340/2011-12/GZB dismissed the appeal of the assessee on the ground of non condonation of delay in filing of appeal. However, the id. CIT(A) in his above referred order held that the appellant should have filed rectification application under section 154 before the A.O. subject to the genuineness and correctness of its claims and time limit involved. 4) The assessee after the order of CIT(A) filed a reminder before the A.O. dated 22.10.2012 requesting for disposal of its application under section 154 dated 28.05.2009. The A.O., however, vide order dated 30.03.2013 rejected the application filed by the assessee on the ground that the CIT(A), Ghaziabad has dismiss....

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....As regards the assessee's contention that Form 15H in respect of the depositors as shown in the list submitted in the office of the Commissioner of Income Tax in as much as the interest paid to other depositors was less than Rs.5,000/- in each case, the same cannot be entertained on merits at this stage. Proceedings are accordingly revised under section 154 of the Income Tax Act, 1961. 3. The calculation of short charge, interest under section 201(1A) upto the date of order under section 201 (l) i.e. up to June, 2008, penalty under sec. 271C and interest under section 220(2) from July, 2008 to March, 2015 is as under:- Sr.No. Asstt. Year Amount of interest Short charge Intt. Upto June, 2008 Intt. u/s 220(2) upto March,2015 Tota....