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Issues:
1. Interpretation of provisions under section 209A(1)(a) and section 217(1A) of the Income-tax Act, 1961. 2. Justification of interest charged for non-filing of statement of advance tax. Analysis: Issue 1: Interpretation of provisions under section 209A(1)(a) and section 217(1A) of the Income-tax Act, 1961: The case involved a dispute regarding the filing of a statement of advance tax under section 209A(1)(a) of the Income-tax Act, 1961. The assessee had filed estimates of advance tax instead of the required statement. The Assessing Officer charged interest under section 217(1)(a) for non-compliance. However, the Commissioner of Income-tax (Appeals) canceled the interest, considering the estimates filed by the assessee. The Tribunal upheld this decision, emphasizing that the facts found by the Commissioner of Income-tax (Appeals) were correct. The court analyzed the assessment order and the nature of interest charged, concluding that interest was levied under section 217(1A) and not section 217(1)(a). The court clarified that section 217(1A) applies when an estimate is not filed, not when the statement under section 209A is missing. As the interest was charged under section 217(1A), the court held that the assessee had satisfied the provisions, and no interest could be levied under section 217. Issue 2: Justification of interest charged for non-filing of statement of advance tax: The Assessing Officer had charged interest under section 217(1)(a) due to the non-filing of the statement of advance tax by the assessee. The Commissioner of Income-tax (Appeals) overturned this decision based on the estimates filed by the assessee. The court examined the assessment order and the nature of the interest charged, determining that interest was levied under section 217(1A) and not section 217(1)(a). The court emphasized that section 217(1A) applies when an estimate is not filed, not when the statement under section 209A is missing. As the interest was charged under section 217(1A), the court held that the assessee had fulfilled the requirements, and no interest could be imposed under section 217. Consequently, the court answered both questions in the reference in the affirmative and in favor of the assessee, with no order as to costs. This judgment clarifies the distinction between sections 209A(1)(a) and 217(1A) of the Income-tax Act, 1961, regarding the filing of advance tax statements and the levy of interest for non-compliance. It underscores the importance of correctly applying the provisions of the Act and ensuring that interest charges align with the specific requirements outlined in the legislation.
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