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TMI Blog2022 (5) TMI 447X X X X Extracts X X X X X X X X Extracts X X X X ..... erest u/s 234B of the Act after the date of 154 order - HELD THAT:- Considering assessee submission that AO has erred in charging interest from first day of assessment year which the passing of rectification order u/s 154 and the ld. AR also substantiated with the chart referring the dates on which the payments have been made and further submitted that an opportunity to provide for substantiate be ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssed u/s 271(1)(c) and 250 of the Act. The assessee has raised the following grounds of appeal: Principal of Natural Justice Violated: 1. The id CIT(A) erred in passing the impugned order dated 20/09/2021 exparte without considering/ dealing with the assessee's application for adjournment filed on 14/09/2021 wherein i t was intimated that assessee had tested Covid positive and copy of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Y till passing the order u/s 154 dated 14.02.2020 on the total amount determined without taking into consideration the payments made in the intervening period. 3. The assessee craves leave to add, amend, alter or delete any or all the above grounds of appeal. 2. The brief facts of the case that the assessee has filed the return of income for the A.Y 2013-14 on 27.01.2014 with total incom ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ismissed the appeal of and confirmed the calculations made u/s 234B of the. Aggrieved by the order the assessee has filed an appeal before the Hon ble Tribunal. 4. At the time of hearing the Ld. AR of the assessee submitted that the CIT(A) erred in confirming the levy of interest u/s 234B in the rectification petition without considering the fact that prior passing the rectification order u/s 1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... een made and further submitted that an opportunity to provide for substantiate before the lower authorities, the Ld. DR has no specific objection. Considering the overall facts, circumstances and details we are of the opinion that the matter has to be reworked accordingly we restore the entire disputed issue to the file of the AO for limited purpose along with evidences in the course of hearing to ..... X X X X Extracts X X X X X X X X Extracts X X X X
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