Interest on settlement application pendency disallowed where admitted tax and final liability were timely paid.

Interest under Section 245D(2C) was held not leviable for the period when the settlement application remained pending before the Settlement Commission, because the admitted tax was paid when the application was filed, the additional amount was deposited within the stipulated time after admission, and the final tax liability was also discharged. The Delhi HC noted that the concurrent factual findings of the Commissioner (Appeals) and the Tribunal disclosed no error warranting interference, so the Revenue's challenge failed.

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Issues: Whether interest under Section 245D(2C) of the Income-tax Act, 1961 could be levied for the period during which the settlement application remained pending before the Settlement Commission, where the admitted tax had been deposited within time and the final tax liability was also satisfied.

Analysis: The admitted tax liability had been paid when the settlement application was filed, and the further amount required after admission was deposited within the stipulated time. The final tax liability determined by the Settlement Commission was also discharged. On these facts, the levy of interest for the pendency period was unwarranted, and the concurrent factual findings of the Commissioner (Appeals) and the Tribunal showed no error requiring interference.

Conclusion: Interest under Section 245D(2C) was not leviable in the facts of the case, and the challenge by the Revenue failed.

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