TMI Blog1999 (8) TMI 50X X X X Extracts X X X X X X X X Extracts X X X X ..... t 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 was not entitled to get 'interest on interest' on the sum paid in pu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 language of section 244(1A) requires the payment of simple interest at the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in sub-section (1) on the amount so found to be in excess from the date on which such amount was paid to the date the refund is granted. In view of this plain language of the provisions of sub-section (1A), no substantial question of law does arise for which the appeal is considered. The application for appeal is rejected. All parties are to act on a xeroxed signed copy of this dictated order on ..... X X X X Extracts X X X X X X X X Extracts X X X X
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