1992 (11) TMI 45

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..... y the second respondent by order dated March 31, 1976, on a total income of Rs. 1,14,000 as evidenced by exhibit P-1. Later, the third respondent initiated reassessment proceedings after issuing notice under section 148 of the Income-tax Act. He completed the reassessment under section 143(3) read with section 147(a) by order dated November 22, 1981, and withdrew the sales tax liability of Rs. 82, .....

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..... Rs. 79,688. Exhibit P-3 is the order. The petitioner filed a petition before the Inspecting Assistant Commissioner of Income-tax, Trichur, for cancelling the interest levied under sections 139(8) and 217. Thereafter, the Income-tax Officer passed an order under section 154 for giving effect to the direction of the Inspecting Assistant Commissioner and interest under sections 139(8) and 217 was r .....

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..... in the original assessment, there cannot be any levy of interest in the order of reassessment has been considered in exhibit P-7 order. It is true that interest was levied for the first time in the order of reassessment made on November 22, 1981. Section 139(8) does not prohibit levy of interest when reassessment is made. It also does not specifically mention that levy of interest can be made only .....

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