The assessee was directed to make a representation to the CBDT under s 119(2) either for the waiver of interest or to condone the delay in filing the rectification application under s 154, since on account of a mistake, the interest income was offered to tax and the tax was also paid on it, as held by SCI in Housing And Urban Dev Corp Ltd v JCIT — In favour of: Others; Special Leave to Appeal (Civil) No(s) 12002/2011.
It is impermissible in a review petition for an assessee to re-argue and re-agitate the issues/questions which have been already considered and decided by the High Court, as held by DelHC in Ravina Khurana v CIT — In favour of: The revenue; RP No 358/2011 in WP (C) No 340/2010.
CA Saiprasad P. Bagrecha
Ph:020-2701 9233 Fax : 020- 2701 9233 Mob:- +91- 98235 26824 / + 91-82750 32822
"It's best to have failure happen early in life. It wakes up the Phoenix bird in you so you rise from the ashes."
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