In a One Time Settlement of principal & interest, it cannot be assumed that assessee has paid the interest due

The assessee has not produced any evidence to indicate the apportionment of the OTS amount of Rs.91 lacs towards principal and interest. It is obvious that a part of above amount was towards interest for the OTS amount was admittedly more than Rs.72 lacs (principal amount).

The assessee having failed to produce any  documents or other evidence in this regard, we see no reason to speculate in its favour. The working of the proportionate amount by the assessee is not based on what infact transpired between SICOM and itsel

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