https://www.taxtmi.com/caselaws?id=36510 The Tribunal's decision to dismiss the appeal by the assessee against the Appellate Assistant Commissioner's ruling was overturned by the court. The court held that the excess interest paid under Section 214(1A) should be treated as tax payable, making it appealable under Section 246(c) of the Income Tax Act, 1961. The court rejected the revenue's argument that the excess interest was not appealable, emphasizing that the legal fiction introduced by Section 214(1A) should be applied fully. As a result, the court ruled in favor of the assessee, granting the right to appeal and ordered parties to bear their own costs. en-us Wed, 08 Mar 1978 00:00:00 +0530 Mon, 22 Mar 2010 17:19:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=36510 The Tribunal's decision to dismiss the appeal by the assessee against the Appellate Assistant Commissioner's ruling was overturned by the court. The court held that the excess interest paid under Section 214(1A) should be treated as tax payable, making it appealable under Section 246(c) of the Income Tax Act, 1961. The court rejected the revenue's argument that the excess interest was not appealable, emphasizing that the legal fiction introduced by Section 214(1A) should be applied fully. As a result, the court ruled in favor of the assessee, granting the right to appeal and ordered parties to bear their own costs. Case-Laws Income Tax Wed, 08 Mar 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=36510