Section 234B interest requires a specific assessment order direction; bona fide belief-based deletion raised a substantial question of law.

Interest under section 234B could not be included in the notice of demand under section 156 for assessment year 1991-92 because the assessment order contained only a general direction to "charge interest" and no specific direction to levy that interest; on that issue, no substantial question of law arose. For assessment year 1990-91, the deletion of interest based on the assessee's bona fide belief that its income was not taxable raised a substantial question of law and warranted further hearing on merits.

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Issues: Whether the deletion of interest under section 234B of the Income-tax Act, 1961 for assessment year 1991-92 gave rise to any substantial question of law, and whether the deletion of such interest for assessment year 1990-91 required adjudication on merits.

Analysis: For assessment year 1991-92, the assessment order contained only a general direction to "charge interest" and no specific direction to levy interest under section 234B. In view of the governing precedent that interest under section 234B cannot be included in the notice of demand under section 156 unless specifically directed in the assessment order, no substantial question of law arose on that aspect. For assessment year 1990-91, the Tribunal had deleted the interest on the basis of the assessee's bona fide belief that its income was not chargeable to tax, and the Court found that this issue involved a substantial question of law warranting admission of the appeal.

Conclusion: The appeal was admitted only in respect of assessment year 1990-91, while no substantial question of law arose for assessment year 1991-92.

Final Conclusion: The Court confined further hearing to the interest levy dispute for assessment year 1990-91 and declined to entertain the challenge for assessment year 1991-92.

Ratio Decidendi: Interest under section 234B cannot be included in the demand unless the assessment order contains a specific direction to charge it; a mere general direction to "charge interest" is insufficient.

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