Regular assessment under advance tax law means the original assessment, not a later appellate giving-effect order.

For section 214 of the Income-tax Act, 1961, "regular assessment" was treated as the first or original assessment for the year, so interest on excess advance tax was confined to the period ending with that assessment. A later assessment made only to give effect to appellate relief did not extend the interest period or change the point at which liability arose. The refusal to grant interest was also not regarded as an apparent mistake capable of rectification under section 154. On that basis, the claim for further interest and rectification failed.

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Issues: Whether interest on excess advance tax under section 214 of the Income-tax Act, 1961 is payable where the excess is found only after a modified assessment made to give effect to appellate relief, and whether such refusal can be corrected under section 154.

Analysis: The expression "regular assessment" in section 214 was held to refer to the first or original assessment for the year. The Court followed the view that once an assessment order is made, the liability to pay tax arises, and the subsequent setting aside, modification, or recomputation of that assessment does not alter the point of time up to which interest on excess advance tax is payable. The contrary view, treating the order giving effect to appellate relief as the relevant regular assessment, was not accepted. On the rectification point, the refusal of interest was not treated as an obvious or patent mistake capable of correction under section 154.

Conclusion: The assessee was not entitled to interest on the excess advance tax beyond the date of the first or original assessment, and the claim for rectification failed.

Final Conclusion: The petition was dismissed, and the revenue authorities' view that interest under section 214 was confined to the period ending with the original assessment was upheld.

Ratio Decidendi: For purposes of section 214, "regular assessment" means the original assessment order for the year, and a later order made to give effect to appellate relief does not extend the period for interest on excess advance tax.

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