1999 (8) TMI 50

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....ing for the assessee submits that the following question, referred at page 4 of the memorandum of appeal is a substantial question of law, which requires interpretation : "Whether, on the facts and in the circumstances of the case and on a judicious interpretation of section 244(1A) of the Income-tax Act, 1961, the Income-tax Appellate Tribunal was justified in law in holding that the appellant....

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....is made to the assessee. But in case of interest payable under section 214 after the date of assessment, no interest for the period from the date of assessment order is payable under section 214 to the date of payment of interest. In this view of the Act, we cannot put at par the interest payable under section 244(1A) with the interest payable under section 214 of the Act of 1961. The plain lan....