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TMI Blog2019 (1) TMI 846X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee. We find that the assessee has denied receiving any such show cause notice from the AO and as there is nothing on record to show that the show cause notice issued by the AO was served on the assessee. In view of the above, we direct the AO to pass a fresh order, after giving reasonable opportunity of being heard to the assessee - Appeal of the assessee is partly allowed for statistical purposes. - ITA No:- 2920/Del/2015 - - - Dated:- 15-1-2019 - SHRI K.N. CHARY, JUDICIAL MEMBER AND SHRI ANADEE NATH MISSHRA, ACCOUNTANT MEMBER For The Assessee : Shri Rohit Jain, Adv. and Ms. Tejasvi Jain, Adv. For The Revenue : Shri Surender Pal, Sr. DR ORDER PER ANADEE NATH MISSHRA, AM This appeal by Assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... roup company under their TAN No. DELG08746D for the relevant assessment year under consideration. 6. Status of challans deposited by the appellant s group company as reflecting in the Department s NSDL website. 7. Copy of the acknowledgment of revised statement of TDS dated 14.05.2012 under section 200(3) of the Income Tax Act, 1961 for the relevant assessment year under consideration 8. Copy of the letter dated 25.04.2012 filed before the assessing officer for obtaining the justification report. 9. Copy of the rectification application dated 19.05.2012 filed before the assessing officer under section 154 of the Act. 10. Coy of submission dated 12.02.2015 filed before CIT(A) 11. CIT vs. Gujarat Fluro Chem ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Ld. CIT(A) were wrong in holding that the Assessee was liable to pay interest on interest U/s 201(1)/201(1A) of I.T. Act. (4) The Ld. Departmental Representatives ( DR , for short) submitted that the interest on interest was not charged U/s 201(1)/201(1A) of the Act, but U/s 220 of I.T. Act, in accordance with law. In rejoinder, the Ld. Counsel for Assessee submitted that, on perusal of the order dated 26.12.2012 of AO, it is not clear whether the interest on interest was charged U/s 220 of I.T. Act or U/s 201(1)/201(1A) of I.T. Act. (5) We have heard both sides carefully and perused the materials available on record. We have considered the judicial precedents which were brought to our attention. On perusal of the records, we fin ..... X X X X Extracts X X X X X X X X Extracts X X X X
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