Penalty U/s. 221(1) for default in payment of demand cannot exceed tax amount

On reading the provisions of section 221 conjointly with the definition of “tax” as detailed under section 2(43), the irresistible conclusion that can be drawn is that the phraseology “tax in arrears” as envisaged in section 221 of the Act would not take within its realm the interest component. It would be abundantly clear that the assessing officer can impose penalty for default in making the p

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