Retrospective amendment to delayed return interest upheld, leaving the assessee liable to pay interest on late filing.

Retrospective amendment to the interest provision under the Income-tax Act was held to govern delayed filing of return, so the assessee remained liable for interest despite the prior position. The operative effect of the amendment was that the levy could not be resisted once retrospectivity was accepted, and the authorities were justified in rejecting the assessee's challenge and charging interest accordingly.

---

---

Issues: Whether the assessee was liable to pay interest in view of the retrospective amendment to the provision governing interest on delayed filing of return.

Analysis: The appeal turned on the effect of the retrospective amendment to Section 234A of the Income-tax Act, 1961. Once the amendment was held to operate retrospectively, the assessee could not resist the levy of interest. The authorities were therefore justified in rejecting the assessee's claim and in charging interest accordingly.

Conclusion: The liability to interest was upheld and the contention of the assessee failed.

---