1995 (3) TMI 57

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..... referred the following question of law arising out of its order dated September 3, 1984, in respect of the assessment year 1972-73 : " Whether, on the facts and in the circumstances of the case, the Appellate Tribunal was justified in not upholding the interest charged by the Income-tax Officer under sections 139(8) and 217 of the Income-tax Act, 1961, while completing the assessment for the fir .....

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..... r of the Appellate Assistant Commissioner, it was directed that recalculation be made accordingly. In the second appeal before the Income-tax Appellate Tribunal, it was observed that the assessment under section 147 is not a regular assessment and, therefore, interest under sections 217 and 139(8) cannot be charged. It was also submitted that even the first assessment under section 148 cannot be c .....

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