1982 (9) TMI 90

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....eal are that the assessee had paid advance tax, which resulted in a refund of Rs. 1,989, after the completion of the regular assessment. The assessee claimed that he was entitled to receive interest due u/s 214 and with this idea in view, he moved an application u/s 154 dt. 29th September 1980 before the ITO. The ITO turned down this application by passing a very cryptic order as stated below: ....

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....vember and December were apparently not made by the prescribed dates and, therefore, as held by several High Courts, were not entitled for interest u/s 214. Therefore, according to him, the AAC had misled himself in directing the ITO to allow interest u/s 214. 4. We have looked into the facts of the case and it does not appear that we can subscribe to the submission made by the revenue in this ....