CENTRAL PROVINCES MANGANESE ORE CO. LTD. vs COMMISSIONER OF INCOME TAX

The Supreme Court held that the levy of interest under Section 139(8) and Section 215 of the Income-tax Act, 1961 is part of the assessment process and can be disputed in appeal if the assessee claims they are not liable for the levy. The Court clarified that such interest is not a penalty but a compensation for the Revenue's loss due to delayed payment. The appeals were dismissed as the Court found that the orders levying interest are not appealable under Section 246 when an appeal is pending, as per Section 264(4)(b).