(1.) THIS matter arises out of the order of the Income-tax Appellate Tribunal, dated January 28, 1983, in respect of the assessment year 1977-78. The Tribunal has referred the following two questions of law arising out of the said order for opinion of this court :
(2.) WHETHER; on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was right in confirming the order of the Income-tax Officer withdrawing interest originally allowed under Section 214 and charging interest under Section 215 originally not charged ?"
(3.) THE provisions of Section 199 of the Income-tax Act as amended by the Act No. 11 of 1987 are as under :