2025 (12) TMI 1514

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....tter dated 17.12.2025 the assessee has sought to raise an additional ground, challenging the validity of the order passed u/s. 154 of the Act on account of non-mentioning of document identification number (DIN). Be that as it may, we propose to deal the issue on merits. 3. Briefly stated, the assessee is a resident corporate entity. For the assessment year under dispute, the assessee filed its return of income on 14.03.2022, declaring total income of Rs. 55,22,22,410/-. Though initially, the return of income was processed u/s. 143(1) of the Act, however, subsequently, it was selected for scrutiny. In course of assessment proceeding, the Assessing Officer (A.O. for short) called for various details and after examining them ultimately, con....

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....e Act is consequential and automatic. He observed, since in the original notice of demand issued u/s. 156 of the Act nil demand was shown as a result of computational error, the demand crystalized after the rectification order passed u/s. 154 of the Act would have retrospective effect from the date of the original assessment order. Accordingly, he upheld the levy of interest u/s. 220(2) of the Act. 6. Being aggrieved, the assessee is before us. At the time of hearing, ld. Counsel appearing for the assessee primarily reiterated the submission made before the first appellate authority. Further, he relied upon the following decisions: 1. Vodafone Mobile Service Ltd. vs. Union of India [2013] 31 taxmann.com 213 (Del) 2. Bha....

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....0 days from the service of such notice on an assessee. However, as per the proviso to sub section (1) of section 220, the 30 days period can be curtailed with previous approval of superior authority. Sub section (2) of section 220, provides that in case the amount specified in the notice of demand issued u/s. 156 of the Act is not paid within the period specified therein, the assessee shall be liable to pay simple interest at 1% for over month or part of a month comprised in period commencing from the day immediately falling the end of the period mentioned in sub section (1) and ending on the day on which the amount is paid. Though, in the provisos to sub section (2) to section 220, certain exceptions have been provided, however, presently ....