One assessee has submitted an appeal before the Commissioner of Income Tax (Appeals) against the order u/s 144 of the IT Act. After submission of the appeal, the assessee was waiting for the date of hearing. Meanwhile, the Income Tax Officer issued a notice under section 154 of the Income Tax Act and increase the demand previously created under the head interest. There was no compliance of notice under section 154 of the IT Act issued by the Income Tax Officer. Now the question is German in respect of the amount of total demand which has to be filed in the prescribed form of Vivad Se Vishwas No 1. Whether the interest increased by virtue of rectification, subsequently after furnishing of appeal can be the subject matter of the Vivad Se Vishwas. There shall be a mismatch in demand reflected in the appeal and actual demand because in the appeal the amount of tax and interest has to be mentioned. Whereas the present demand is more than the original because the demand has been increased by way of the order passed under section 154 of the IT Act.
The part of increased interest is related to 115 BBE and even in the ground of appeal, this ground has been taken.
Hope you will let me know your esteem opinion.
With regards
Sumitra Maru