P.N. Parashar, J.M. - (1.)THESE cross-appeals, filed by the revenue as well as by the assessee, arise out of the order of Commissioner (Appeals) dated 21-8-2002, relating to the assessment year 1997-98. Both the appeals were heard together and are being disposed of by this order.
(2.)Shri Ajay Vohra, advocate along with Shri Rohit Jain, advocate, Shri Gaurav Jain, chartered accountant; Shri S.C. Agarwal, Vice President (Taxation), and Shri Virendra Sharma, Manager (Taxation), appeared on behalf of the assessee whereas Shri L.M. Pandey, CIT-departmental Representative along with Shri R.L. Meena, Departmental Representative represented the revenue.
ITA No. 3925/Del/2002 (Assessee's appeal):

Ground No. 1 : This ground is as under:

That on law, facts and in the circumstances of the case, the learned Commissioner (Appeals) has erred in upholding the addition of Rs. 1,06,146 made by the assessing officer in respect of payment of interest under Section 201 (1A) for delay in deposit of TDS while computing the book profit under Section 115JA of the Income Tax Act, 1961.

3.1 The assessee company was carrying on the business of manufacturing and trading of pharmaceuticals/bulk drug. During the year under consideration, the assessee company showed total turnover at Rs. 1,114.56 crores. The assessing officer after examining the various details of balance sheet and profit and loss account, filed along with the r