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The only issue is whether the levy of interest under Sections 234 A, 234 B and 234 C of the Act is to be waived or not.

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Section 234A, 234B and 234C of the Income Tax Act, 1961 — Advance tax — If adverse judicial or quasi judicial decision are to furnish a cause for seeking waiver of interest, it would have been expressly stated in clause (2ea) as in clause (2d) and when a person embarks on the journey of litigation, he should be prepared for an adverse verdict, therefore, there is nothing unforeseeable about the outcome of judicial or quasi judicial proceeding — Tushin T Mehta vs. Chief Commissioner of income tax [2019] 417 ITR 529 (Madras)

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