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TMI Blog2013 (12) TMI 1371X X X X Extracts X X X X X X X X Extracts X X X X ..... st Revenue. Interest u/s 234A, 234B and 234C - Held that:- Following CIT Vs. Ranchi Club Ltd [2000 (8) TMI 79 - SUPREME Court] - Even if any provision of law is mandatory and provides for charging of tax or interest - Such charge by the assessing officer should be specific and clear and assessee must be made to know that the assessing officer has applied its mind and has ordered charging of in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ment Year 1991-92, by which the Tribunal partly allowed the assesee's appeal and dismissed the revenue's appeal. 3. This appeal was admitted on the following questions of law:- "1. Whether the Hon'ble Tribunal is justified in upholding the order of the CIT (A) in accepting Rs.10,87,245/- as sale proceeds as subsequently claimed by the assessee during the appellate proceedings as against additi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e findings given in the assessee's appeal, the revenue appeal did not require for consideration. 6. Since the order of the Tribunal had attained finality in the appeal filed by the assessee, we do not propose to consider the same grounds all over again, which resulted into dismissal of revenue's appeal. 7. We also find and observe that the question of acceptance of Rs.10,87,245/- as sale proce ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... issed on merits. The facts stated in the note published in ITR demonstrate that the High Court had held that the order of the assessing authority in the assessment order to charge interest is to be specific and clear and the assessee must be made to know that the assessing officer after applying its mind has ordered charging of interest. We do not find that the judgment in Ranchi Club Ltd. has eit ..... X X X X Extracts X X X X X X X X Extracts X X X X
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