9911796707
TMI Blog1983 (8) TMI 133X X X X Extracts X X X X X X X X Extracts X X X X ..... Rs. 32,688 had been shown, which came to less than 12.5%, and expenses to the extent of Rs. 2,40,015 were not verifiable. He, therefore estimated the net profit at 15% on receipts of Rs. 2,40,015 which came to Rs. 36,000. On appeal, the AAC confirmed the estimate on the ground that the assessee himself had shown a net profit of 15% for the subsequent year. Therefore, no interference was called for ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... The next dispute relates to the liability for payment of interest. The ITO noticed that the return had been filed on 6th Oct., 1977 in response to a notice u/s 148. He, therefore, initiated penalty proceedings u/s 271(1)(a) and also charged interest u/s 139 (8). On appeal, it was argued before the AAC that the provision contained in sub. s. (8) of s. 139 was compensatory in the nature. In the pre ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ducted at source. Now, in the present case, after adjusting the advance-tax and the tax deducted at source, the assessee was found entitled to a refund of Rs. 4,650. Therefore, apparently, no interest was payable u/s 139(8), because the interest is to be paid on the balance amount of assessed tax, after deducting the tax paid in advance and deducted at source. This ground is, therefore, allowed. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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