Revision against interest under section 234B barred after appellate proceedings already covered the assessment demand.

Interest under section 234B was treated as an integral part of the assessment and the appellate orders, so revisional interference under section 264 was unavailable once the assessment demand had already been carried in appeal. The High Court therefore upheld the rejection of the revision as inadmissible against the interest component. The pending waiver application was not decided in these proceedings and did not alter the maintainability issue.

---

---

Issues: Whether a revision under section 264 of the Income-tax Act, 1961, was maintainable against levy of interest under section 234B when the assessment order had already been the subject of appellate proceedings.

Analysis: Interest levied under section 234B formed an integral part of the assessment and the appellate orders. Since the demand arising from the assessment had already been carried in appeal, revisional interference under section 264 could not be invoked against the interest component. The separate waiver application remained pending and was not adjudicated in these proceedings.

Conclusion: The revision was not maintainable against the levy of interest under section 234B, and no illegality was found in the impugned order rejecting the revision as inadmissible.

---