1985 (8) TMI 143

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..... limited to an amount calculated at the prescribed rate for a period between 1st April 1981 and the date of expiry of one full year from the dates of filing of the return. The ITO completed the assessment on 23rd Jan. 1984 and charged interest or Rs. 13,215 under s. 217 (1A). The assessee contested the levy on the ground that it arose as a result of disallowances made in the assessment order and su .....

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..... ive reiterated the grounds, according to which levy of interest under s. 217 was not appealable and the power to invoke r. 40 was not vested with the CIT. The ld. Representative of the assessee supported the order of the CIT (A). 4. After due consideration we hold that the CIT having rejected the claim for total waiver of interest as untenable ought not to have given a direction to the ITO to ap .....

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