Section 193 — Form of appeal and memorandum of cross-objections to Appellate Tribunal under section 362

(1) An appeal under section 362(1) or (2) to the Appellate Tribunal shall be made in Form No. 115, and where the appeal is made by the assessee, theform of appeal, the grounds of appeal and the form of verification appended thereto, shall be signed by the person specified in rule 167(3).
(2) A memorandum of cross-objections under section 362(4) to the Appellate Tribunal shall be made in Form No. 116, and where the memorandum of cross-objection is made by the assessee, the form of memorandum of cross-objections, the grounds of cross-objections and the form of verification appended thereto,shall be signed by the person specified in rule 167(3).

Related sections

Section 1 — In exercise of powers conferred by section 533 of the Income-tax Act, 2025 (30 of 2025), the Central Board of Direct Taxes hereby makes the following rules,namely:– Short title and commencement
Section 2 — Definitions
Section 3 — Arrangements for declaration and payment of dividends within India
Section 4 — Conditions that a stock exchange is required to fulfil to be notified as a recognised stock exchange under section 2(92)
Section 5 — Procedure for notification of a recognised stock exchange for the purposes of section 2(92)
Section 6 — Method of determination of period of holding of capital assets in certain cases
Section 7 — Procedure for notification of zero coupon bond
Section 8 — Computation of period of stay in India for an Indian citizen, being a member of the crew of a foreign bound ship
Section 9 — Determination of income in case of non-residents
Section 10 — Definition of terms for rules 11 and 12
Section 11 — Fair market value of assets in certain cases
Section 12 — Determination of income attributable to assets in India
Section 13 — Threshold for purposes of significant economic presence
Section 14 — Method for determining amount of expenditure in relation to income not includible in total income
Section 16 — Annual accretion referred to in section 17(1)(i)
Section 17 — Salary income for purposes of section 17(1)(c)(ii)
Section 18 — Exemption of medical benefits from perquisite value in respect of medical treatment of prescribed diseases or ailments in hospitals approved by theChief Commissioner
Section 19 — Gross total income for purposes of section 17(3)(b)
Section 20 — Procedure for purposes of section 19 [Table: Sl. No. 12] relating to voluntary retirement or voluntary separation
Section 21 — Unrealised rent
Section 22 — Computation of aggregate average advances for purposes of section 31(1) [Table: Sl. No. 1] for deduction for provision of bad and doubtful debt
Section 23 — Computation of pro rata amount of discount on a zero coupon bond for purpose of section 32(d)
Section 24 — Notification of infrastructure facility for the purposes of section 32(e)
Section 25 — Depreciation
Section 26 — Cases and circumstances in which a payment or aggregate of payments exceeding ten thousand rupees may be made to a person in a day, otherwisethan by specified banking and online mode or through such other electronic mode as provided in rule 48
Section 27 — Form of statement to be furnished regarding certain preliminary expenses eligible for deduction under section 44
Section 28 — Form of audit report for claiming deduction for certain preliminary expenses under section 44 and expenditure for prospecting certain mineralsunder section 51
Section 29 — Prescribed authority and process of approval for expenditure on scientific research under section 45(1)(a)(ii) and (2)
Section 30 — Prescribed authority and process of approval for expenditure on scientific research under section 45(3)(c)
Section 31 — Furnishing of statement of particulars in respect of donation and certificate to donor under section 45(4)(a)
Section 32 — Procedure, form and manner in respect of approval under section 45(4) read with section 45(3)(a) for deduction for expenditure on scientific researchby a research association
Section 33 — Conditions subject to which approval is to be granted to a research association for deduction for expenditure on scientific research under section45(4) read with section 45(3)(a)
Section 34 — Conditions subject to which approval is to be granted to a University, college or other institution for deduction for expenditure on scientific researchunder section 45(4) read with section 45(3)(a)
Section 35 — Prescribed authority, procedure, form, manner and conditions for approval by a company for deduction for expenditure on scientific research undersection 45(3)(b)
Section 36 — Procedure for notification of an affordable housing project as a specified business under section 46(11)(d)(vii) and a semi-conductor wafer fabricationmanufacturing unit as a specified business under section 46(11)(d)(xiii)
Section 37 — Procedure for approval of agricultural extension project under section 47(1)(a)
Section 38 — Conditions for notification of agricultural extension projects under section 47(1)(a)
Section 39 — Procedure for approval of skill development projects under section 47(1)(b)
Section 40 — Conditions subject to which a skill development project is to be notified under section 47(1)(b)
Section 41 — Expenditure for obtaining right to use spectrum for telecommunication services
Section 42 — Special provision regarding interest on bad and doubtful debt of specified financial institution
Section 43 — Form of report of audit to be furnished under section 59(4) for computation of royalty and fee for technical services
Section 44 — Conditions to be fulfilled by a non-resident, engaged in the business of operation of cruise ships under section 61(2) [Table: Sl. No. 2]
Section 45 — Conditions to be fulfilled by a resident company for purposes of section 61(2) [Table: Sl. No. 6]
Section 46 — Maintenance of books of account under section 62
Section 47 — Report of audit of accounts to be furnished under section 63
Section 48 — Other electronic modes of payment
Section 49 — Computation of capital gains for purposes of section 67(5)
Section 50 — Attribution of income taxable under section 67(10) to capital assets remaining with the specified entity, under section 72
Section 51 — Other conditions required to be fulfilled by the original fund
Section 52 — Rate of exchange for conversion of rupees into foreign currency and reconversion of foreign currency into rupees for purpose of computation ofcapital gains under section 72
Section 53 — Computation of fair market value of capital assets for purposes of section 77
Section 54 — Form of report of an accountant in respect of slump sale
Section 55 — Conditions for reference to Valuation Officers under section 91(1)(b)
Section 56 — Meaning of expressions used in determination of fair market value
Section 57 — Determination of fair market value
Section 58 — Prescribed class of persons for the purpose of section 92(3)(i) and section 79
Section 59 — Computation of income chargeable to tax under section 92(2)(l)
Section 60 — Conditions for carrying forward or set-off of accumulated loss and unabsorbed depreciation allowance in case of amalgamation
Section 61 — Certificate of a medical authority in respect of autism, cerebral palsy and multiple disabilities for the purposes of deduction under section 127 andsection 154
Section 62 — Issuance of prescription in respect of certain diseases and ailments for the purpose of deduction under section 128
Section 63 — Prescribed authority for approval of a University or any educational institution of national eminence for purposes of section 133
Section 64 — Procedure for specifying an association or institution for purposes of notification under section 133(1)(a)(xxiv)
Section 65 — Conditions for claim for deduction under section 134
Section 66 — Furnishing of audit report for claiming deduction under section 46 or 138 or 139 or 140 or 141 or 142 or 143 or 144
Section 67 — Form of particulars to be furnished along with return of income for claiming deduction under section 144
Section 69 — Report of accountant to be furnished under section 147(4)(a)
Section 70 — Form of certificate to be furnished under section 151(5)
Section 71 — Prescribed authority and form of certificate to be furnished under section 152(5)
Section 72 — Prescribed authority and form of certificate to be furnished under section 151(6) and section 152(6)
Section 73 — Relief under section 157(1), when salary is paid in arrears or in advance, gratuity, etc
Section 74 — Taxation of income from retirement benefit account maintained in a notified country
Section 75 — Other documents and information to be provided for claiming double taxation relief under section 159(1) and (2)
Section 76 — Foreign tax credit
Section 77 — Meaning of expressions used in determination of arm's length price
Section 78 — Other method for determination of arm's length price
Section 79 — Determination of arm's length price under section 165
Section 80 — Most appropriate method
Section 81 — Determination of arm's length price in certain cases
Section 82 — Exercise of option for determination of arm's length price for multiple years in a singleproceeding
Section 83 — Time period for repatriation of excess money under section 170(2) and computation ofinterest income under section 170(4) pursuant to secondaryadjustments
Section 84 — Information and documents to be kept and maintained under section 171(1)
Section 85 — Report from an accountant to be furnished under section 172
Section 86 — Definitions for safe harbour rules for international transactions
Section 87 — Eligible assessee for safe harbour rules for international transactions
Section 88 — Eligible international transactions for safe harbour
Section 89 — Safe harbour for eligible international transactions
Section 90 — Procedure relating to transactions other than provision of information technology services
Section 91 — Procedure relating to transactions of provision of information technology services
Section 93 — Mutual agreement procedure not to apply where Safe harbour for international transactions is accepted
Section 94 — Definitions for safe harbour rules for specified domestic transaction
Section 95 — Eligible assessee for safe harbour rules for specified domestic transactions
Section 96 — Eligible specified domestic transaction for safe harbour
Section 97 — Safe harbour for eligible specified domestic transaction
Section 98 — Procedure governing safe harbour rules for specified domestic transactions
Section 99 — Definitions for safe harbour rules for income attribution in case of income from business and profession
Section 100 — Safe harbour for income attribution in case of income from business and profession
Section 101 — Procedure governing safe harbour rules for income attribution in case of income from business and profession
Section 102 — Mutual agreement procedure not to apply where safe harbour for income attribution in case of income from business and profession is exercised
Section 103 — Meaning of expressions used in matters in respect of advance pricing agreement
Section 105 — Pre-filing consultation
Section 106 — Application for advance pricing agreement
Section 107 — Withdrawal of application for agreement
Section 108 — Preliminary processing of application
Section 109 — Procedure
Section 110 — Terms of the agreement
Section 111 — Roll back of Agreement
Section 112 — Amendments to application
Section 113 — Furnishing of annual compliance report
Section 114 — Compliance audit of agreement
Section 115 — Revision of an agreement
Section 116 — Cancellation of an agreement
Section 117 — Procedure for giving effect to rollback provision of an Agreement
Section 118 — Relief in tax payable under section 206(1) due to operation of section 206(1)(i)
Section 120 — Miscellaneous
Section 121 — Application seeking to give effect to terms of any agreement under section 533(2)(p) and procedure for giving effect to decision under agreement
Section 122 — Procedure to deal with requests for bilateral or multilateral advance pricing agreements
Section 123 — Maintenance and furnishing of information and document by constituent entity of an international group under section 171
Section 124 — Furnishing of report in respect of an international group under section 511
Section 125 — Furnishing of authorisation and maintenance of documents, etc. for the purposes of section 176
Section 126 — Conditions and activities for finance company located in any International Financial Services Centre for section 177
Section 127 — Determination of consequences of impermissible avoidance arrangement
Section 128 — Chapter XI relating to General Anti Avoidance Rule not to apply in certain cases
Section 129 — "(2) Without prejudice to the provisions of sub-rule (1)(d), the provisions of Chapter XI shall apply to any arrangement, irrespective of the date on which ithas been entered into, in respect of the tax benefit obtained from the arrangement on or after the 1st April, 2017." Notice and Forms for reference under section 274
Section 130 — Time limits
Section 131 — Procedure before Approving Panel
Section 132 — Remuneration
Section 133 — Modes of payment for the purpose of section 187
Section 134 — Exercise of option for taxation of royalty income from patent under section 194(1) [Table: Sl. No. 2]
Section 135 — Calculation of net winnings from online games for purpose of section 194(1) [Table: Sl. No. 5]
Section 136 — Exercise or withdrawal of option for new tax regime
Section 137 — Form of report for computation of book profit of companies
Section 138 — Form of report for computation of adjusted total income by certain persons other than a company
Section 139 — Computation of exempt income of specified fund attributable to units held by non-resident under Schedule VI [Table: Sl. Nos. 1 to 4] to Act
Section 140 — Determination of income of a specified fund attributable to units held by non-residents under section 210(2)
Section 141 — Computation of exempt income of specified fund, attributable to investment division of an offshore banking unit under Schedule VI [Table: Sl. Nos. 1to 4] to Act
Section 142 — Conditions referred to in Schedule VI [Note 1(g)(ii)(B)] to Act required to be fulfilled by an investment division of an offshore banking unit
Section 143 — Determination of income of a specified fund attributable to investment division of an offshore banking unit under section 210(3)
Section 144 — Other conditions required to be fulfilled by a specified fund as referred to in Schedule VI [Note 1(g)(i)] to Act
Section 145 — Statements under sections 221(4), 222(2), 223(5) and 224(9)
Section 146 — Rules related to application for exercising the option for tonnage tax scheme and other matters related to it
Section 147 — Publication and circulation of order of Board under section 239(3)(a)
Section 148 — Search and Seizure under section 247
Section 149 — Procedure to requisition services under section 247(5) and to make a reference under section 247(9)
Section 150 — Valuation under section 247(9)
Section 151 — Requisition of books of account, etc. under section 248
Section 152 — Release of remaining assets under section 250
Section 153 — Distraint and sale
Section 154 — Form of information under section 254(1)
Section 155 — Disclosure of information related to assessees under section 258(2)
Section 156 — Prescribed income-tax authority under section 259
Section 157 — Persons exempt from obtaining Permanent Account Number under section 262
Section 158 — Application for allotment of a Permanent Account Number
Section 159 — Transactions in relation to which Permanent Account Number is to be quoted or applied for purposes of section 262(1)(f) and 262(10)(c) and (e)
Section 160 — Time and manner in which persons referred to in rule 159 shall furnish a statement containing particulars of Form No. 97
Section 161 — Transactions for purposes of section 262(9)(a)
Section 162 — When PAN becomes inoperative under section 262(6)
Section 163 — Conditions for furnishing return of income by persons other than a company or firm referred to in section 263(1)(a)(x)
Section 164 — Forms, eligibility, verification etc. in respect of return of income
Section 165 — Furnishing of updated return of income under section 263(6) read with [263(2)]
Section 166 — Conditions for treating a return as defective return under section 263(7)
Section 167 — Form of appeal to Joint Commissioner (Appeals) or Commissioner (Appeals) under section 358
Section 168 — Prescribed person for verification of return for purposes of section 265 [Table: Sl. Nos. 3 and 9]
Section 169 — Form of verification for furnishing information under section 268(1)(c)
Section 170 — "I declare that to the best of my knowledge and belief, the information furnished in the statement/statements is correct and complete and other particularsshown therein are truly stated." Prescribed income-tax authority under section 268(3) for issue of notice under sub-section (1) thereof
Section 171 — Forms for report of audit or inventory valuation under section 268(5)
Section 172 — Procedure for purposes of determining expenses for audit or inventory valuation
Section 173 — Jurisdiction of Valuation Officers as per section 2(110) read with section 269
Section 174 — Day and time for inspection by Valuation Officers, etc., as per section 269(3)
Section 175 — Prescribed authority for issue of notice under section 270(8)
Section 176 — Procedure for faceless assessment, reassessment or recomputation under section 273(1)
Section 177 — Modified return of income in respect of business reorganisation under section 314
Section 178 — Application under section 288(1) [Table: Sl. No. 11] regarding credit of tax deduction at source
Section 179 — Notice of demand under section 289
Section 180 — Return of income in respect of block assessment under section 294(1)
Section 181 — Common application for registration of non-profit organisation or for approval for the purposes of deduction under sec-tion 133(1)(b)(ii)
Section 182 — Manner of computation of gains of commercial activities under sections 335(e), 344, 345 and 346
Section 183 — Manner of computation of any portion of income applied by a registered non-profit organisation, directly or indirectly, for benefit of any relatedperson
Section 184 — Exercise of options by a registered non-profit organisation under section 341(7) for deemed application under section 341(5)
Section 185 — Furnishing of statement by registered non-profit organisation under section 342(1) for accumulating or setting apart any part of its regular income
Section 186 — Application under section 342(5) for change of purpose for which income has been accumulated or set apart
Section 187 — Books of account and other documents to be kept and maintained by a registered non-profit organisation
Section 188 — Report of audit in case of registered non-profit organisations under section 348
Section 189 — Method of valuation for the purposes of computing fair market value of assets and liabilities under section 352(2) for accreted income
Section 190 — Furnishing of statement of particulars in respect of donation and certificate to donor under section 354(1)
Section 191 — Mode of service of any order referred to in section 358(3)(b)
Section 192 — Production of additional evidence before Joint Commissioner (Appeals) and Commissioner (Appeals) under section 533(2)(x)
Section 194 — Declaration under section 375
Section 195 — Application under section 376 to defer filing of appeal before Appellate Tribunal or the jurisdictional High Court
Section 196 — Constitution of Dispute Resolution Committee under section 379
Section 197 — Application for resolution of dispute before the Dispute Resolution Committee under section 379
Section 198 — Power to reduce or waive penalty imposable or grant immunity from prosecution or both under section 379
Section 199 — Definitions
Section 200 — Application for obtaining an advance ruling under section 383
Section 201 — Certification of copies of advance rulings pronounced by Board for Advance Rulings under section 384(8)
Section 202 — Form and manner of filing appeal to High Court on ruling pronounced or order passed by Board for Advance Rulings under section 389(1)
Section 203 — Credit for tax deducted or collected at source
Section 204 — Furnishing of particulars for deduction of tax at source from income under head "Salaries"
Section 205 — Furnishing of evidence of claims by employee under section 392(5)(b) for deduction of tax from income under head "Salaries"
Section 206 — Rate of exchange for conversion into rupees of income expressed in foreign currency
Section 207 — Rate of exchange for the purpose of deduction of tax at source on income payable in foreign currency
Section 208 — Furnishing of declaration and evidence of claims by specified senior citizen under section 393(1) [Table: Sl. No. 8(iii)]
Section 209 — Application by payee for certificate authorising receipt of interest and other sums without deduction of tax
Section 211 — Declaration by person claiming receipt of certain incomes without deduction of tax under section 393(6)
Section 212 — Declaration by a buyer for no collection of tax at source under section 394(2)
Section 213 — Application for grant of certificates for deduction or collection of income-tax at any lower rates, or no deduction of income-tax
Section 214 — Application by payer for grant of certificate under section 395(2) or section 400(3) for determination of appropriate proportion of sum (other thansalary), payable to non-resident, chargeable in case of recipients
Section 215 — Certificate of tax deducted or collected at source to be furnished under section 395(4)
Section 216 — Application for allotment of a tax deduction and collection account number
Section 217 — Conditions under section 397(2)(c) for non-application of deduction of tax at higher rate, in case of non-residents
Section 218 — Time and mode of payment to Government account of tax deducted or collected at source or tax paid under section 392(2)(a)
Section 219 — Statement of deduction or collection of tax at source under section 397(3)(b)
Section 220 — Furnishing of information for payment to a non-resident, not being a company, or to a foreign company
Section 221 — Form for furnishing certificate of accountant under section 398(2) for person responsible for deduction or collection of tax as per section 394(1)[Table: Sl. Nos. 1 to 5 and 9] not to be deemed to be an assessee in default
Section 222 — Notice of demand under section 289
Section 223 — Estimate of advance tax under section 407(8)
Section 226 — Tax recovery officer to exercise or perform certain powers and functions of an Assessing Officer under section 413
Section 227 — Prescribed authority for tax clearance certificates under section 420
Section 228 — Forms and certificates for the purposes of section 420
Section 231 — Form of application under section 440
Section 232 — Service of notice, summons, requisition, order and other communication under section 501
Section 233 — Authentication of notices and other documents
Section 234 — Furnishing of annual statement by a non-resident having liaison office in India
Section 235 — Information or documents to be furnished under section 506
Section 236 — Form of statement to be furnished by producers of cinematograph films or persons engaged in specified activity
Section 237 — Furnishing of statement of financial transaction
Section 238 — Definitions
Section 239 — Information to be maintained and reported
Section 240 — Due diligence requirement
Section 241 — Definitions for purposes of rules 242, 243 and 244
Section 242 — Obligation for reporting transaction of crypto-asset under section 509
Section 243 — Reporting requirements for transaction of crypto-asset under section 509
Section 244 — Due diligence procedures under section 509
Section 245 — Annual Information Statement
Section 246 — Application for registration as valuer under section 514
Section 247 — Qualification of registered valuer for the purposes of section 514
Section 248 — Charging of fee and submission of valuation report under section 514
Section 249 — Removal from register of names of valuers and restoration
Section 250 — Definitions for the purposes of rules 251 to 268
Section 251 — Accountancy examinations recognised
Section 252 — Educational qualifications prescribed
Section 253 — Nature of business relationship
Section 254 — Appearance by Authorised Representative in certain cases
Section 255 — Register of income-tax practitioners
Section 256 — Application for registration
Section 258 — Cancellation of certificate
Section 259 — Cancellation of certificate obtained by misrepresentation
Section 260 — Removal of name of authorised income-tax practitioner who is insolvent or on whom penalty has been imposed
Section 261 — Prescribed authority to order an inquiry
Section 262 — Charge-sheet
Section 263 — Inquiry Officer
Section 264 — Proceedings before Inquiry Officer
Section 265 — Order of the prescribed authority
Section 266 — Procedure if no Inquiry Officer appointed
Section 268 — Powers of prescribed authority and Inquiry Officer
Section 269 — Procedure to be followed in calculating interest under section 533(2)(u)
Section 270 — Determination of income, being partly from agricultural and partly from business
Section 271 — Income from manufacture of rubber, coffee and tea
Section 272 — Deduction in respect of expenditure on production of feature films
Section 273 — Deduction in respect of expenditure on acquisition of distribution rights of feature films
Section 274 — Procedure for investment fund for availing benefit under section 9(12) read with Schedule I to Act
Section 275 — Approval of the investment fund at its option for purposes of section 9(12)
Section 276 — Statement to be furnished by eligible investment fund under section 9(12) read with Schedule I to the Act
Section 277 — Calculation of taxable interest relating to contribution in a provident fund or recognised provident fund, exceeding specified limit
Section 278 — Conditions for purposes of Schedule III [Table: Sl. No. 8] to the Act
Section 279 — Limits for the purposes of Schedule III [Table: Sl. No. 11] to the Act
Section 280 — Allowances for purposes of Schedule III [Table: Sl. Nos. 12 and 13] to the Act
Section 281 — Circumstances and conditions for purposes of Schedule III [Table: Sl. No. 16] to the Act
Section 282 — Notification of pension fund and other conditions to be satisfied by the pension fund
Section 283 — Computation of minimum investment and exempt income for purposes of Schedule V [Table: Sl. No. 7] to Act
Section 284 — Conditions for the purpose of Schedule VI [Table: Sl. No. 5] to the Act
Section 285 — Computation of exempt income in nature of capital gains in connection with relocation of original fund, etc
Section 286 — Requirements for approval of a fund for welfare of employees and their dependents under Schedule VII [Table: Sl. No. 2] to Act
Section 287 — Percentage of Government grant for considering any University, hospital, or any other institution, as substantially financed by the Government forpurposes of Schedule VII [Table: Sl. Nos. 17 and 18] to Act
Section 288 — Procedure for setting up an Infrastructure Debt Fund for purpose of exemption under Schedule VII [Table: Sl. No. 46] to Act
Section 289 — Rules for functioning of an electoral trust
Section 290 — Report of audit of accounts to be furnished under Schedule IX read with section 48 for deduction for tea development account, coffee developmentaccount and rubber development account
Section 291 — Report of audit of accounts to be furnished under Schedule X read with section 49 for deduction for site restoration fund
Section 292 — Investment of fund moneys
Section 293 — Nomination
Section 294 — Accounts
Section 296 — Application for recognition
Section 297 — Order of recognition
Section 298 — Withdrawal of recognition
Section 300 — Appeal under paragraph 13(1) of Part A of Schedule XI to the Act
Section 301 — Definitions for purposes of rules 302 to 315
Section 302 — Conditions regarding trust and trustees
Section 303 — Investment of fund moneys
Section 305 — Ordinary annual contributions
Section 306 — Initial contributions
Section 307 — Scheme of insurance or annuity
Section 308 — Commutation of annuity
Section 309 — Beneficiary not to have any interest in insurance and employer not to have any interest in moneys of fund
Section 310 — Penalty, where employee assigns or charges interest in fund
Section 312 — Arrangements for winding up, etc., of fund
Section 313 — Application of approval
Section 314 — Amendment of rules, etc., of fund
Section 315 — Appeal under paragraph 9(1) of Part B of Schedule XI to the Act in case of superannuation fund
Section 316 — Definitions for purposes of rules 317 to 329
Section 317 — Conditions regarding trust and trustees
Section 318 — Investment of fund moneys
Section 319 — Nomination
Section 320 — Admission of directors to a fund
Section 321 — Ordinary annual contributions
Section 322 — Initial contributions
Section 324 — Employer not to have interest in fund moneys
Section 325 — Arrangements for winding up, etc., of business
Section 326 — Arrangements for winding up of the fund
Section 327 — Application for approval
Section 328 — Amendment of rules, etc., of fund
Section 329 — Appeal under paragraph 9(1) of Part B of Schedule XI to the Act in case of gratuity fund
Section 330 — Limits of reserve for unexpired risks
Section 331 — Procedure for approval under paragraph (1)(z)(i) and (ii) of Schedule XV to the Act
Section 332 — Electronic furnishing of Forms, returns, statements, reports, orders, certificates, etc
Section 333 — Electronic payment of tax, interest, fee and penalty