1982 (2) TMI 120

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... interest amounting to Rs. 1,380 allowed under s. 244(1A) by way of rectification under s. 154, which is arbitrary and unjustified. 2. That the provisions of s. 154 are not applicable in the instant case as there is no mistake apparent from record which could be rectified under s. 154. 3. That the order of the 1d. AAC upholding the order of the ITO is erroneous, arbitrary, opposed to law and .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... r submitted that the issue being not free from debate it could not be rectified under s. 154. The AAC, however, confirmed the action of ITO and rejected the first appeal of the assessee in this regard. 4. While contesting the action of the AAC, the 1d. Counsel for the assessee reiterated the same submissions as made before the AAC that the payment of interest of Rs. 1,380 under s. 244(1A) was i .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... granted interest in the amount of Rs. 1,380. He did not see any debate about the issue and vehemently argued that the order of the AAC being in order, deserves to be confirmed. 6. After taking into consideration the rival submissions, we are unable to accept the contentions of the 1d. Dept1. Rep. on the short ground that the issue regarding grant of interest is not free from debate under s. 244 .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X