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Interest on Tax Default Requires Structured Calculation Process to Address Taxpayer Disputes.

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....Demand of interest u/s 50 - default in filing the Return - The High court acknowledged that while the liability to pay interest is automatic, the quantification cannot be unilateral. It must involve an arithmetic exercise where the taxpayer's objections are considered. Cited the “Mahadeo Construction” case to support the view that quantification of interest liability must involve a proper process, especially when disputed by the taxpayer.....