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Interest Calculation for Tax Defaults: Tribunal Rules 36-Month Charge Valid; Taxpayer May Object to Recalculation.
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....The case involves the computation of interest under section 234B for defaults in payment of advance tax. The Appellate Tribunal held that interest was correctly charged under section 234B(1) for the 36-month period from April 2010 to March 2013 based on the first assessment under section 153A. The subsequent appellate order only impacts the assessed income and tax liability, not the period for interest levy. Section 234B(3) applies when there is no first-time assessment under section 147/153A. Interest is to be charged based on the tax liability determined in the appellate proceedings for the mentioned 36-month period. The AO is directed to recompute interest in line with the Tribunal's order, allowing the assessee to raise objections if needed to avoid further litigation.....