Appealability of section 214 interest claim turns on whether the assessment challenge also contests advance tax liability.

A challenge to the assessment that necessarily contests advance tax liability and the resulting interest under section 214 is appealable before the Appellate Assistant Commissioner. The assessee's grievance was not confined to the quantum of interest; it went to the computation of total income and, consequentially, the liability to advance tax and interest. On that footing, the appeal lay and refusal to entertain it was erroneous. A mere objection to the amount of interest charged would stand differently, but that was not the substance of the dispute.

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Issues: Whether the claim relating to interest under section 214 was appealable before the Appellate Assistant Commissioner on the facts of the case.

Analysis: The assessee's challenge to the computation of total income necessarily affected the interest payable under section 214 and also impliedly disputed the quantum of advance tax liability. Where the assessment of income is questioned in a manner that, if accepted, would reduce the liability to advance tax and the consequential interest, the matter is appealable. A mere objection to the quantum of interest charged stands on a different footing, but that was not the real substance of the present grievance.

Conclusion: The issue was appealable and the Appellate Assistant Commissioner was wrong in refusing to entertain it. The matter was restored to the Appellate Assistant Commissioner for disposal on merits, in favour of the assessee.

Ratio Decidendi: An appeal lies where the assessee's challenge to the assessment necessarily contests the liability to advance tax and thereby affects consequential interest under section 214; a challenge limited only to the quantum of interest is not enough.

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