Compensatory interest under separate tax defaults may both apply, and a settlement body cannot review its own order.

Interest under section 139(8) compensates delay in filing the return, while interest under sections 215/217 compensates default in payment of advance tax; because the two provisions address different defaults, there was no legal bar to levying both where the facts justified it. The Settlement Commission also had no power to review its own order, and the later petition was considered on merits as well, so the assessee showed no prejudice from not treating it as a mere correction application. The challenge to the levy of interest and to the handling of the subsequent petition therefore failed.

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Issues: Whether interest under section 139(8) and interest under sections 215/217 of the Income-tax Act, 1961 could both be levied, and whether the Settlement Commission erred in treating the assessee's later petition as one for review rather than correction.

Analysis: Interest under section 139(8) is compensatory for delay in filing the return, while interest under section 215 is compensatory for default in payment of advance tax. The two provisions operate on different defaults and there was no legal bar to levy of both where the facts justified it. The Commission had no power to review its own order, and the later petition was considered on merits as well, so no prejudice was shown in not treating it as a mere correction application.

Conclusion: The challenge to the levy of interest and to the manner in which the subsequent petition was dealt with failed.

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