Central Provinces Manganese Ore Co. Ltd. v. CIT

160 ITR 961Supreme Court of India1986#3775 most cited

What is Central Provinces Manganese Ore Co. Ltd. v. CIT authority for?

The levy of interest under the Income Tax Act is part of the assessment process and can be challenged in an appeal if the assessee disputes the chargeability of interest itself. However, claims for waiver or reduction of interest cannot be challenged in appeal and must be pursued through revisional jurisdiction.

31

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2009 to 2025.

Also referred to as

Central Provinces Manganese Ore Co. Ltd. v. CIT · section 215 · section 234A · section 234B · section 246 · appeal against interest · chargeability of interest · waiver of interest

Sections most often in play

Section 139(5)Section 139(8)Section 143(1)Section 154Section 215Section 234ASection 246ASection 250
Read the full judgment

Issues it is cited on

section 215section 21section 234bsection 234section 23companyinterest

Judgments citing Central Provinces Manganese Ore Co. Ltd. v. CIT

The Commissioner of Income Tax Delhi-II vs. Maha Maya General Finance Limited

ITA-285/2007HC Delhi27 Feb 2009
Section 234BSection 260A

…Section 234B was not of a penal nature and was clearly compensatory in nature and, therefore, the same could be levied retrospectively. He referred to the decision of the Supreme Court in the case of Central Provinces Manganese Ore Co. Ltd v. CIT: [1986] 160 ITR 961, which was rendered in the context of Section 215 of the said Act which is similar to Section 234B of the said Act. The Supreme Court observed that it was necessary to consider the nature of levy of interest under Section 139 (8) and Section 215. The Supreme Court observed:- “it is not correct to refer to the levy of such interest as a pe…

The Commissioner of Income Tax Delhi-II vs. Anand Prakash

ITA-121/2007HC Delhi27 Feb 2009
Section 234BSection 260A

…Section 234B was not of a penal nature and was clearly compensatory in nature and, therefore, the same could be levied retrospectively. He referred to the decision of the Supreme Court in the case of Central Provinces Manganese Ore Co. Ltd v. CIT: [1986] 160 ITR 961, which was rendered in the context of Section 215 of the said Act which is similar to Section 234B of the said Act. The Supreme Court observed that it was necessary to consider the nature of levy of interest under Section 139 (8) and Section 215. The Supreme Court observed:- “it is not correct to refer to the levy of such interest as a pe…

The Commissioner of Income Tax Delhi-II vs. Maha Maya General Finance Limited

ITA-300/2007HC Delhi27 Feb 2009
Section 234BSection 260A

…Section 234B was not of a penal nature and was clearly compensatory in nature and, therefore, the same could be levied retrospectively. He referred to the decision of the Supreme Court in the case of Central Provinces Manganese Ore Co. Ltd v. CIT: [1986] 160 ITR 961, which was rendered in the context of Section 215 of the said Act which is similar to Section 234B of the said Act. The Supreme Court observed that it was necessary to consider the nature of levy of interest under Section 139 (8) and Section 215. The Supreme Court observed:- “it is not correct to refer to the levy of such interest as a pe…

The Commissioner of Income Tax Delhi-II vs. Anand Prakash

ITA-122/2007HC Delhi27 Feb 2009
Section 234BSection 260A

…Section 234B was not of a penal nature and was clearly compensatory in nature and, therefore, the same could be levied retrospectively. He referred to the decision of the Supreme Court in the case of Central Provinces Manganese Ore Co. Ltd v. CIT: [1986] 160 ITR 961, which was rendered in the context of Section 215 of the said Act which is similar to Section 234B of the said Act. The Supreme Court observed that it was necessary to consider the nature of levy of interest under Section 139 (8) and Section 215. The Supreme Court observed:- “it is not correct to refer to the levy of such interest as a pe…

The Commissioner of Income Tax Delhi-II vs. Anand Prakash

ITA-120/2007HC Delhi27 Feb 2009
Section 234BSection 260A

…Section 234B was not of a penal nature and was clearly compensatory in nature and, therefore, the same could be levied retrospectively. He referred to the decision of the Supreme Court in the case of Central Provinces Manganese Ore Co. Ltd v. CIT: [1986] 160 ITR 961, which was rendered in the context of Section 215 of the said Act which is similar to Section 234B of the said Act. The Supreme Court observed that it was necessary to consider the nature of levy of interest under Section 139 (8) and Section 215. The Supreme Court observed:- “it is not correct to refer to the levy of such interest as a pe…

The Commissioner of Income Tax Delhi-II vs. Anand Prakash

ITA-119/2007HC Delhi27 Feb 2009
Section 234BSection 260A

…Section 234B was not of a penal nature and was clearly compensatory in nature and, therefore, the same could be levied retrospectively. He referred to the decision of the Supreme Court in the case of Central Provinces Manganese Ore Co. Ltd v. CIT: [1986] 160 ITR 961, which was rendered in the context of Section 215 of the said Act which is similar to Section 234B of the said Act. The Supreme Court observed that it was necessary to consider the nature of levy of interest under Section 139 (8) and Section 215. The Supreme Court observed:- “it is not correct to refer to the levy of such interest as a pe…

The Commissioner of Income Tax Delhi-II vs. Maha Maya General Finance Limited

ITA-298/2007HC Delhi27 Feb 2009
Section 234BSection 260A

…Section 234B was not of a penal nature and was clearly compensatory in nature and, therefore, the same could be levied retrospectively. He referred to the decision of the Supreme Court in the case of Central Provinces Manganese Ore Co. Ltd v. CIT: [1986] 160 ITR 961, which was rendered in the context of Section 215 of the said Act which is similar to Section 234B of the said Act. The Supreme Court observed that it was necessary to consider the nature of levy of interest under Section 139 (8) and Section 215. The Supreme Court observed:- “it is not correct to refer to the levy of such interest as a pe…

The Commissioner of Income Tax Delhi-II vs. Maha Maya General Finance Limited

ITA-299/2007HC Delhi27 Feb 2009
Section 234BSection 260A

…Section 234B was not of a penal nature and was clearly compensatory in nature and, therefore, the same could be levied retrospectively. He referred to the decision of the Supreme Court in the case of Central Provinces Manganese Ore Co. Ltd v. CIT: [1986] 160 ITR 961, which was rendered in the context of Section 215 of the said Act which is similar to Section 234B of the said Act. The Supreme Court observed that it was necessary to consider the nature of levy of interest under Section 139 (8) and Section 215. The Supreme Court observed:- “it is not correct to refer to the levy of such interest as a pe…

The Commissioner of Income Tax Delhi-II vs. Anand Prakash

ITA-116/2007HC Delhi27 Feb 2009
Section 234BSection 260A

…Section 234B was not of a penal nature and was clearly compensatory in nature and, therefore, the same could be levied retrospectively. He referred to the decision of the Supreme Court in the case of Central Provinces Manganese Ore Co. Ltd v. CIT: [1986] 160 ITR 961, which was rendered in the context of Section 215 of the said Act which is similar to Section 234B of the said Act. The Supreme Court observed that it was necessary to consider the nature of levy of interest under Section 139 (8) and Section 215. The Supreme Court observed:- “it is not correct to refer to the levy of such interest as a pe…

The Commissioner of Income Tax Delhi-II vs. Anand Prakash

ITA-118/2007HC Delhi27 Feb 2009
Section 234BSection 260A

…Section 234B was not of a penal nature and was clearly compensatory in nature and, therefore, the same could be levied retrospectively. He referred to the decision of the Supreme Court in the case of Central Provinces Manganese Ore Co. Ltd v. CIT: [1986] 160 ITR 961, which was rendered in the context of Section 215 of the said Act which is similar to Section 234B of the said Act. The Supreme Court observed that it was necessary to consider the nature of levy of interest under Section 139 (8) and Section 215. The Supreme Court observed:- “it is not correct to refer to the levy of such interest as a pe…

The Commissioner of Income Tax Delhi-II vs. Maha Maya General Finance Limited

ITA-297/2007HC Delhi27 Feb 2009
Section 234BSection 260A

…Section 234B was not of a penal nature and was clearly compensatory in nature and, therefore, the same could be levied retrospectively. He referred to the decision of the Supreme Court in the case of Central Provinces Manganese Ore Co. Ltd v. CIT: [1986] 160 ITR 961, which was rendered in the context of Section 215 of the said Act which is similar to Section 234B of the said Act. The Supreme Court observed that it was necessary to consider the nature of levy of interest under Section 139 (8) and Section 215. The Supreme Court observed:- “it is not correct to refer to the levy of such interest as a pe…