Bachawat, J.

1. DURING the financial year 1947-48 the assesses was called upon to pay in advance a sum of Rs. 11,00,494/- as tax payable in respect of the assessment year 1948-49 under Section 18A(1) of the Indian Income Tax Act. The assessee submitted under Section 18A(6) its own estimate of the tax and on the basis of such estimate paid a sum of Rs. 4,47, 125/-. The assessment for the assessment year 1948-49 was made on 29-4-1950 and as the tax paid by the assessee on the basis of its own estimate was less than eighty per cent of the tax determined on such assessment, the assessee was charged with interest amounting to Rs. 92,301-12-0 under Section 18A(6). The assessee paid this amount on 7-7-1950, i.e. in the previous year corresponding to the assessment year 1951-52. DURING the assessment proceedings for the assessment year 1951-52 the assessee claimed that the sum of Rs. 92,501-12-0 was an allowable deduction in arriving at its taxable profits. The Income-tax Officer disallowed the claim without assigning any reason. On Appeal the Appellate Assistant Commissioner confirmed the disallowance and held that the deduction was not permissible under Sections 10(2) (iii) and 1