Re: 234D interst

The interest under 234D is charged while passing order vide section 154 along with quantum addition . I am in appeal from that order . I applied for rectification of order vide section 154 . Another order is passed stating that 234d is correctly charged
If i settle the dispute for the first order can i file the appeal from second order and get relief with refeence to intest under section 234D . The second rectification order is after cutoff date of Vsvs

Please refer  circular No . 9 /2020 dt 22-4 -2020--Q, No . 42 and answer   given by the CBDT,    which state that any amount paid in pursuance of a declaration made under the Vivad Se Vishawas shall not be refundable under any circumstances .  Please  also refer Section 5 (3) of the  Direct  Tax Vivad Se Vishwas Act , 2020, every order passed under  sub section 5(1) , determining the amount payable under this Act  shall be conclusive as to the matter stated therein and no matter covered by such order reopened in any proceedings under the Income -tax  Act

 

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