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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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Sec. 220 & 271 of the Income-tax Act, 1961 – Penalty - The case of the petitioner, since the amount of Rs. 3,11,206.00 (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. Further the Certificate of Intimation also 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. Held: 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. - KUBER BUILDERS V/s UOI - [2020] 272 TAXMAN 216 (BOM)

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