Interest under section 214 was held payable up to receipt of the refund order, following binding precedent.

Interest under section 214 of the Income-tax Act, 1961 was held payable to the assessee for each assessment year up to the date of receipt of the refund order. The Bombay High Court followed its later binding precedent, which had already considered the earlier Full Bench view and the relevant CBDT instructions, and applied the same reasoning to the present reference. On that basis, the question was answered in the assessee's favour and the entitlement to interest up to the refund order date was affirmed.

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Issues: Whether the assessee was entitled to interest under section 214 of the Income-tax Act, 1961, for each of the assessment years under consideration up to the date of receipt of the refund order.

Analysis: A similar question had earlier been answered against the Revenue in a later judgment of the same Court, after considering the earlier Full Bench view and the relevant instructions of the Central Board of Direct Taxes. Following that subsequent binding precedent, the Court applied the same reasoning to the present reference.

Conclusion: The question was answered in the affirmative, holding that the assessee was entitled to interest under section 214 of the Income-tax Act, 1961, up to the date of receipt of the refund order, in favour of the assessee.

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