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TMI Blog2021 (9) TMI 448X X X X Extracts X X X X X X X X Extracts X X X X ..... the Tribunal in upholding the power of Assessing Officer to levy of interest u/s 234A of the Act in the proceedings u/s 154 of the Act cannot co-exist - HELD THAT:- We find that the averment of the Revenue before us is correct. On mere reading of para 4 of the impugned order (supra), it would suggest that the tenor of order of Tribunal is not to uphold the validity of initiation of proceedings u/s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of proceedings u/s 154 of the Income Tax Act, 1961 ( the Act ) by the Assessing Officer is valid and the finding of the Tribunal in upholding the power of Assessing Officer to levy of interest u/s 234A of the Act in the proceedings u/s 154 of the Act cannot co-exist. Thus, it is averred that the order passed by Tribunal required to be rectified. 2. We have carefully gone through the present ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n the matter in the said precedent and considering the commonality of the facts of all the three cases, we are of the opinion that the Assessing Officer assumed jurisdiction u/s 154 of the Act is validly. Consequential common ground nos.2 and 3 raised by the assessee in all the three appeals are allowed. Substituted Para- 5. Considering the above se ..... X X X X Extracts X X X X X X X X Extracts X X X X
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