Interest demand without a direction in the assessment order could not stand; no substantial question of law arose.

Interest under sections 234B and 234C of the Income-tax Act could not be sustained where the assessment order contained no direction levying such interest. The Tribunal had deleted the demand on the basis of settled precedent that a notice of demand for interest can issue only when the assessment order expressly directs its levy. In the absence of any such direction, the Delhi HC found no substantial question of law arising from the Revenue's section 260A challenge, and the appeal was dismissed.

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Issues: Whether interest under sections 234B and 234C of the Income-tax Act, 1961 could be sustained in the absence of a direction in the assessment order and whether any substantial question of law arose from the Tribunal's order.

Analysis: The appeal was filed under section 260A of the Income-tax Act, 1961. The Tribunal had deleted the interest charged under sections 234B and 234C, relying on authoritative precedent that a notice of demand claiming interest can be issued only where the assessment order contains a direction levying such interest. It was noted that there was no direction in the assessment order in the present case for charging interest under sections 234A and 234B, and the settled legal position left no room for a substantial question of law.

Conclusion: The challenge to deletion of interest failed, and the appeal was dismissed.

Final Conclusion: The demand of interest could not be sustained without a corresponding direction in the assessment order, and the Revenue's appeal did not give rise to any substantial question of law.

Ratio Decidendi: Interest under the relevant charging provisions cannot be demanded unless the assessment order itself contains a direction levying such interest, and in the absence of such direction no substantial question of law arises.

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