Advance tax interest under section 18A(8) applies to unpaid balance, and no separate interest order is required.

Under section 18A(8) of the Income-tax Act, 1922, interest was chargeable on the amount of advance tax remaining unpaid, including cases of partial non-payment after adjustment of a refund. The reference to the manner laid down in section 18A(6) was treated as a computation mechanism only, not as a limit on the substantive liability under section 18A(8). The provision did not require a separate order awarding interest as a condition precedent; inclusion of the computed interest in the assessment form accompanying the demand notice was sufficient.

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Issues: (i) Whether, under section 18A(8) of the Income-tax Act, 1922, interest could be charged where only part of the advance tax demand remained unpaid after adjustment of a refund. (ii) Whether a separate order determining or awarding the amount of interest was before the sum could be charged.

Issue (i): Whether, under section 18A(8) of the Income-tax Act, 1922, interest could be charged where only part of the advance tax demand remained unpaid after adjustment of a refund.

Analysis: The expression "no payment of tax has been made" was construed as comprehensive enough to cover cases of partial non-payment. The reference in sub-section (8) to the manner laid down in sub-section (6) was treated as a reference only to the method of calculation of interest and not as making sub-section (6) control the applicability of sub-section (8). The liability created by sub-section (8) therefore operated on the amount of advance tax remaining unpaid.

Conclusion: The charge of interest was valid and the issue was decided against the assessee.

Issue (ii): Whether a separate order determining or awarding the amount of interest was required before the sum could be charged.

Analysis: Sub-section (8) required the interest to be calculated in the prescribed manner and added to the tax determined on regular assessment. The Act did not prescribe a separate order awarding interest as a condition precedent. Inclusion of the amount in the assessment form accompanying the demand notice was sufficient compliance.

Conclusion: No separate order was necessary and the issue was decided against the assessee.

Final Conclusion: The statutory scheme under section 18A fastened liability to interest on unpaid advance tax, and the assessment form could validly include the computed amount without any independent order; the appeal therefore failed.

Ratio Decidendi: Under section 18A(8) of the Income-tax Act, 1922, interest is chargeable on the amount of advance tax remaining unpaid, and the provision requiring calculation in the manner of sub-section (6) is only a machinery provision for computation, not a limitation on the substantive liability or a requirement of a separate interest order.

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