1. This reference raises the question with regard to the liability of the assessee company to pay tax on interest received by to in respect of advance payment of at. Under section 18A (5) the assessee company received interest in the sum of Rs. 7,519 in respect of advance payment of tax. Under section 18A the assessee company, which is under a statutory obligation to make this advanced payment, received interest which is calculated at the rate mentioned in sub-section (5) from the date of payment till the date of assessment, and this amount aggregated to Rs. 7,519. There is also provision under sub-section (6) and (7) for payment of interest by the assessee if under sub-section (6) it fails to pay advance tax which is less than 80 per cent. of the tax which it is ultimately assessed to pay, and if under sub-section (7) it fails to pay the tax in proportion to the installment in which the tax is payable; and a liability arose the assessee company to pay interest at 6 per cent. it having committed default under sub-section (7) of section 18A and the amount of this liability was assessed at Rs. 4,554. In the assessment year 1952-53 the Taxing Department brought the sum of Rs.