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Issues: Whether interest under section 214 of the Income-tax Act, 1961 is payable on excess tax deducted at source refunded after assessment.
Analysis: The assessment was completed under section 143(3) of the Income-tax Act, 1961, and the excess amount collected by way of tax deduction at source was refunded without interest. Following the earlier view that there is no provision for payment of interest on excess TDS and that section 214 applies only to advance tax payments, the claim for interest on the refunded TDS amount was not sustainable.
Conclusion: Interest under section 214 is not allowable on excess tax deducted at source; the reference was answered in favour of the Revenue and against the assessee.
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