Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria
4. That the documents, explanations filed by the Appellant, and the material available on record have not been properly considered and judicially interpreted and have been wrongly ignored. 5. That in view of the facts and circumstances of the case, the Assessing Officer has .erred in law and on facts in charging the interest under Sections 234A, 234B, & 234C