Interest on excess advance tax under Section 214 remained enforceable despite later circulars and had to be granted as directed.

Excess advance tax paid by the assessee triggered entitlement to interest under Section 214, and the tax authority's refusal to grant it lacked effective justification. The Commissioner's revisional direction ordering payment of appropriate interest remained binding, and later administrative circulars could not override that statutory obligation or defeat the revisional order. The authorities were therefore required to implement the Commissioner's direction by passing orders granting the interest.

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Issues: Whether the assessee was entitled to interest under Section 214 of the Income-tax Act, 1961 on the refund arising from advance tax paid, and whether the income-tax authorities were bound to comply with the Commissioner's revisional direction granting such interest.

Analysis: The assessee had paid advance tax in excess of the assessed tax and the Commissioner, in exercise of revisional power, had directed grant of appropriate interest under Section 214. The non-grant of interest by the Income-tax Officer was not supported by any effective justification. Administrative circulars issued subsequently could not override the statutory obligation or defeat the earlier revisional order. The duty to grant interest under the Act remained enforceable.

Conclusion: The assessee was entitled to interest under Section 214, and the respondents were bound to implement the Commissioner's order by passing appropriate orders granting such interest.

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