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The appeal by the assessee was against the order of CIT(A), New Delhi, for the asst. yr. 1985-86. The delay in filing the return resulted in interest being charged for 8 months initially and then for 9 months under s. 154 of the Act. The Tribunal held that as there was a cleavage of judicial opinion on the issue, s. 154 cannot be applied, and decided in favor of the assessee. The appeal was allowed.
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