We have heard learned counsel for the parties. Initially, multiple issues were agitated before us, but eventually, we have confined our consideration only to one aspect of making the comprehensive scheme for optout.
The appeals filed by the assessee for AY 1994-95 and 1996-97 were delayed by 2984 days. The assessee claimed that he was advised by his CAM/s Rajesh Rajeev Associatesthat since he had already filed an appeal for AY 1993-94 which was pending before th
Held by hon"ble court that as the assesse had filed a revised return and paid the tax due within the time allowed u/s 148 hence,it cannot be held that assessee had made any delay in payment of tax. As such no interest u/s 234B can be levied.