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There is force in the submissions made by the petitioner that the Certificate of Intimation does not give the precise period for which the penalty and interest has been computed/calculated by the Revenue and merely gives a lumpsum computation and further that the petitioner is not liable to pay any interest and penalty as levied.

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Section 220 & 271 of the Income-tax Act, 1961—Penalty—Computation/calculation of penalty and interest for the said assessment year in the Certificate of Intimation dated 26-2-1999 was not justified as certificate of Intimation does not give the precise period for which the penalty and interest under section 220(2) read with Sections 271(1)(a), 271(1)(b) and 271(1)(c) has been computed/calculated by the Revenue and since the amount of tax liability was deposited by the petitioner in the year 1991 and the same was adjusted by the Revenue for the outstanding demand for assessment year 1987-88, the petitioner could not have been held to be liable to pay any penalty and interest which has been computed in the Certificate of Intimation issued on 26-2-1999. - KUBER BUILDERS V/s UOI - [2020] 26 ITCD Online 130 (BOM)