Advance tax tendered on the next working day after a Sunday due date was not belated, preserving interest entitlement.

Where the advance tax due date fell on a Sunday, local cheques tendered on the next working day, received by the assessing officer, honoured by the bank and credited to the Government account were not treated as belated payment. On that basis, interest under section 214 could not be denied, and the Commissioner had no basis to invoke revision under section 263 merely to disturb the allowance of interest. The Tribunal's cancellation of the revision order was therefore upheld, with the issue decided in favour of the assessee and against the Revenue.

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Issues: Whether, on the facts and in the circumstances of the case, the Commissioner was justified in invoking revision under section 263 of the Income-tax Act, 1961, to deny interest under section 214 on the footing that the advance tax had been paid belatedly.

Analysis: The advance tax due date fell on a Sunday. The assessee tendered local cheques on the next working day, which were received by the assessing officer, honoured by the bank, and credited to the Government account. On these facts, the payment could not be treated as belated so as to disentitle the assessee to interest under section 214. The assessing officer's allowance of interest was therefore not erroneous in a manner warranting interference under section 263.

Conclusion: The Tribunal was justified in cancelling the Commissioner's order under section 263, and the issue was decided in favour of the assessee and against the Revenue.

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