- (1.) The present appeals have been filed by the assessee against the consolidated judgment and order dated 22.8.2008 passed by the Income Tax Appellate Tribunal, Delhi in I.T.A. No.810-815/Del/07 for the assessment years 1989-90 to 1994-95.
(2.) On 12.5.2009, a Coordinate Bench has admitted the appeals on the following substantial questions of law: "A. Whether on the facts and circumstances of the case, the Income Tax Appellate Tribunal was confirmed to confirm the imposition of interest, specially when the assessee has not committed any default under the Income Tax Act so as to attract the provisions of Section 234A, 234B and 234C of the Income Tax Act and still the interest would be chargeable under these provisions because charging of interest under Sections 234A, 234B and 234C of the Act is mandatory xxx xxx xxx E. Whether the Income Tax Appellate Tribunal rightly confirmed the charging of interest from the assessment year 1989-90 to 1994-95 when on due dates of each assessment years the appellant did not had any taxable income casting upon him liability to file income tax return under Sections 139 (1) or 139 (the Act and also that no notice under Section 142 (1) of the Act was served, specially when the appellant was not required to file return till 21.8.2001 when the interest on additional compensation was actually paid to the appellant -
(3.) The brief facts of the case are that the assessee is primarily an agriculturist. His land was acquired by the Government and he got compensation under Section 23 of the Land Acquisition Act, which comprised of three components, namely: A. Compensation u/s 23 (1), B. Additional amount of Compensation u/s 23 (1A); and C. Solatium u/s 23 (2).;