(1.) THIS appeal was admitted on the following questions of law: -
(2.) THOUGH as many as three questions have been framed, after hearing the parties we are of the considered opinion that the real question of law which arises in this case is as follows: -
(3.) SH . Vinay Kuthiala, learned senior counsel appearing for the revenue has placed reliance on the judgment of the Apex Court in Commissioner of Income -tax vs. Anjum M.H.Ghaswala and others (2001) 252 ITR 1, which has clearly laid down that the levy of interest is mandatory. The Constitution Bench of the Apex Court held as follows: -