Appeal against interest levy lies only when liability is denied, not for disputes over computation or waiver.

An objection to interest under section 18A(6) of the Indian Income-tax Act, 1922 was maintainable in appeal only where the assessee denied liability to pay interest at all, or denied liability to be assessed, but not where the challenge was confined to the quantum, computation, method, reduction, or waiver of the interest charged. The statutory scheme distinguishes a root challenge to liability from a dispute over how interest was calculated or whether it should be reduced on discretionary grounds. Accordingly, an appeal lies only against the very existence of liability, not against the amount levied.

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Issues: Whether an objection to the levy of interest under section 18A(6) of the Indian Income-tax Act, 1922 could be raised in an appeal before the Appellate Assistant Commissioner and the Tribunal.

Analysis: The statutory scheme under the 1922 Act and the corresponding provisions of the 1961 Act distinguishes between an appeal that denies the assessee's liability to be assessed at all, or denies liability to pay interest at all, and an objection directed only against the quantum, computation, method, or waiver of interest. The authorities considered show that an appeal lies where the assessee contests the root of assessability or the very liability to interest, but not where the assessee merely disputes the amount charged or seeks reduction or waiver on discretionary grounds. On that footing, the assessee's ground against interest is maintainable only if it is a denial of liability to interest and not a mere challenge to its calculation.

Conclusion: The objection to levy of interest was maintainable in appeal only to the limited extent that the assessee denied its liability to pay such interest at all; a mere challenge to the quantum or mode of levy was not appealable.

Ratio Decidendi: An appeal against interest is competent only when the assessee denies liability to be assessed or denies liability to pay interest altogether, not when the objection is confined to computation, reduction, or waiver of the interest charged.

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