2022 (12) TMI 118

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..... alf of the petitioner that as the dispute was pending for Mutual Agreement Procedure [MAP] resolution which subsequently came to be culminated in the year 2012 and the liability to pay the tax thereafter arose and therefore the petitioner shall be entitled to the waiver of interest u/s 220(2)(A)(ii) of the Act. The aforesaid has no substance. Merely raising the dispute before any authority cann .....

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..... ndra, Adv. Ms. Suhashini Sen, Adv. Mr. Siddhanth Kohli, Adv. Mr. V. Chandrashekhara Bharathi, Adv. Mr. Raj Bahadur Yadav, AOR O R D E R We have heard Mr. Ajay Vohra, learned Senior Advocate, assisted by Ms. Kavita Jha, learned Advocate, appearing for the petitioner and Mr. N. Venkataraman, learned ASG, appearing for the Revenue. The issue involved in the present Special Leave Petition .....

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..... and/or waiver of interest under Section 220(2A) of the Act. Otherwise each and every assessee may raise a dispute and thereafter may contend that as the assessee was bona fidely litigating and therefore no interest shall be leviable. It is required to be noted that under Section 220(2) of the Act, the levy of simple interest on non-payment of the tax @ 1% p.a. is, as such, mandatory. We are in .....

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