Assessment order direction required for interest under sections 234A and 234B; otherwise demand cannot be sustained.

Interest under sections 234A and 234B of the Income-tax Act cannot be recovered through a notice of demand unless the assessment order itself contains a specific direction for levy. Because the assessment order in question contained no such direction, the Tribunal's deletion of the interest was consistent with the settled law and no substantial question of law arose under section 260A. The Revenue's challenge therefore failed and the appeal was dismissed.

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

Analysis: The Tribunal had deleted the interest charged under sections 234A and 234B. The governing view, as affirmed by the Supreme Court, is that a notice of demand claiming interest can be issued only when the assessment order contains a specific direction for levy of such interest. In the present case, the assessment order contained no direction for charging interest under sections 234A and 234B. In these circumstances, the Tribunal's order was consistent with the authoritative pronouncements, and no substantial question of law arose for consideration under section 260A.

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

Ratio Decidendi: Interest under sections 234A and 234B cannot be recovered by a notice of demand unless the assessment order itself contains a specific direction for levy of such interest.

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