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Issues: Whether interest under section 214 of the Income-tax Act, 1961 is payable on the excess amount of tax deducted at source under section 194C of the Income-tax Act, 1961.
Analysis: The Court followed its earlier binding decision holding that sub-section (2) of section 214 applies only to refunds arising from advance tax and not to amounts deducted at source. The expression used in section 214 was treated as referring back to sub-section (1), which deals with advance payment of tax, and not to tax deducted at source.
Conclusion: Interest under section 214 is not admissible on the excess amount of tax deducted at source under section 194C, and the question is answered against the assessee and in favour of the Revenue.
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