AJAY KUMAR MITTAL, J.

1. The revenue has claimed the following substantial question of law in this appeal filed under Section 260A of the Income Tax Act, 1961 (in short “the Act”) against the order dated 28.8.2002 (Annexure A-2) passed by the Income Tax Appellate Tribunal, Chandigarh Bench “B”, Chandigarh (hereinafter referred to as “the Tribunal”) in ITA Nos. 1276, 1277 and 1278/Chandi/1995 for the assessment years 1988-89, 1989-90 and 1990-91:-

(i) Whether on the facts and in the circumstances of the case, the ITAT was right in law in directing the AO to charge interest u/s 201(1A) of the Income Tax Act, 1961 from the due date to the date of actual payment of tax/surcharge either by the person responsible to deduct tax or by the recipient of income, whichever is earlier?

(ii) Whether on the facts and in the circumstances of the case, the ITAT is right in law in directing the AO that the tax paid by the recipient during the previous year, if any, on such income be treated as payment of tax/surcharge under Section 193 of the Income Tax Act, 1961 for calculating interes