Advance tax refund interest under section 214 raised no referable question of law where the provision was clear and supported by precedent.

Section 214(2) of the Income-tax Act was treated as clear in allowing interest on refund of advance tax up to the date of refund, not merely up to the date of regular assessment. That interpretation was supported by Delhi and Madras High Court decisions, and no contrary High Court authority was shown. On that basis, the Tribunal view did not raise any referable question of law for a reference under section 256(1), and the request for reference was declined.

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Issues: Whether any referable question of law arose from the Tribunal's order granting interest on refund of advance tax under section 214 of the Income-tax Act, 1961 up to the date of refund instead of the date of regular assessment.

Analysis: The provision in section 214(2) was treated as clear and not requiring further interpretation. The Tribunal's view was supported by decisions of the Delhi and Madras High Courts, and no contrary High Court view was shown. On that basis, the matter was held not to give rise to a referable question of law for a reference under section 256(1).

Conclusion: No referable question of law arose, and the request for reference was declined.

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