(1.) THE question that has been referred for our consideration is :
(2.) IN the case reported in Modi INdustries Ltd. v. CIT , the Supreme Court has held that Section 214 provides for payment of interest to an assessee on the excess amount of advance tax paid. After adjustment of advance tax at the time of regular assessment, if some balance remains to the credit of the assessee, that balance is treated as excess amount of advance tax which has to be refunded with interest under Section 214.