- (1.) This appeal was admitted for hearing by this Court on 27th September, 2005 on the following substantial questions of law: "a. Whether in the facts and circumstances of the case, the Appellate Tribunal was justified in holding that charging of interest under Section 234B and 234C of the Income Tax Act, 1961 was lawful and proper by calculating and reflecting the same in the Demand Notice without there being any order for charging the said interest and without service of Form No.ITNs 150, if any, in respect thereof upon the assessee appellant. b. Whether the finding of the Appellate Tribunal that the assessment order indicated that interest was charged was perverse."
(2.) This relates to the assessment year 1997-98. The assessee filed its return, the Assessing Officer assessed the total income of the appellant/assessee at Rs. 3,83,23,802/- and after considering all the taxes that have been paid in advance, a sum of Rs. 24,88,485/- was assessed for payment of tax.
(3.) However, after passing the order the assessing officer decided to issue demand notice. The demand notice apart from showing the aforesaid amount of tax liability has also mentioned the payment of interest on the assessed amount of tax.;