SATISH KATOCH,PALAMPUR vs. ITO, PALAMPUR

The appeal of the assessee is dismissed

Bench: The A.O. U/S 154 Of The Act Against

reassessment done subsequently under Section 147 or Section 153A, interest cannot be charged for the first time if the assessee could, not have anticipated the enhancement of income, even if the assessee had taken due care and diligence. This is clear from the decisions cited supra in the case reported in (2000) 69