Advance tax interest period ends on the original assessment date, not a later reassessment date after appeal.

Interest on advance tax under section 18A(5) ran only from payment of advance tax to the date of the original regular assessment. The phrase "the date of the assessment" was construed as the actual date of that assessment, not the date of a later fresh assessment made after the first assessment had been set aside in appeal. A subsequent appellate order or reassessment could not extend the statutory interest period. On that interpretation, the assessee could not claim interest beyond the original assessment date.

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Issues: Whether interest payable on advance tax under section 18A(5) of the Income-tax Act continued up to the date of the fresh assessment made after the original assessment had been set aside in appeal, or only up to the date of the original assessment.

Analysis: Section 18A(5) fixes the period for interest from the date of payment of advance tax to the date of assessment. The expression "the date of the assessment" was construed as the factual date on which the regular assessment was made, and not as the date of some later valid or effective assessment after the first assessment had been set aside. Once interest ceased to run on the original assessment date, that terminus could not be altered by a subsequent appellate order or by the making of a fresh assessment. The assessee's claim to extend the period of interest to the later assessment date therefore failed.

Conclusion: The assessee was not entitled to interest beyond the date of the original assessment, namely 30 March 1948.

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