Appeal against interest levy under tax law held not maintainable before the appellate authority

An order levying interest under section 18A(6) of the Indian Income-tax Act, 1922 was treated as not giving rise to a statutory right of appeal to the Appellate Assistant Commissioner. The court followed the view that such an interest levy was not appealable and found no reason to depart from that position. The question was answered against the assessee, confirming that no appeal lay against the interest order.

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Issues: Whether an appeal lay to the Appellate Assistant Commissioner against an order of the Income-tax Officer levying interest under section 18A(6) of the Indian Income-tax Act, 1922.

Analysis: The levy of interest under section 18A(6) was treated as not giving rise to a maintainable appeal. The Court followed the view that such an order was not appealable and found no reason to depart from that position.

Conclusion: No appeal lay against the order levying interest under section 18A(6) of the Indian Income-tax Act, 1922. The question was answered in the affirmative, against the assessee.

Ratio Decidendi: An order levying interest under section 18A(6) of the Indian Income-tax Act, 1922 does not confer a right of appeal to the Appellate Assistant Commissioner.

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