Y.R.Meena, J. - (1.) By this reference application under Section 256 (2) of the Income-tax Act, 1961, the Tribunal has referred the following questions (question No. 2 is a revised question) for our opinion : "1. Whether, on the facts and in the circumstances of the case, the Tribunal was justified in holding that charging of interest under Section 220(2) of the Income-tax Act, 1961, is not an appealable order ?
(2.) Whether, on the facts and in the circumstances of the case and on a correct interpretation of the relevant provisions of Section 214 of the Income-tax Act, 1961, as it stood at the relevant time the Tribunal was justified in holding that the Assessing Officer was correct and the Commissioner of Income-tax (Appeals) was also justified in confirming the action of the Assessing Officer in withdrawing the interest paid to the assessee under Section 214 of the Income-tax Act which was already refunded to the assessee ?
(3.) Whether, the Tribunal is justified in upholding the charge of interest under Section 220(2) of the Income-tax Act, 1961, amounting to Rs. 42,97,063 and in upholding the order of the Commissioner of Income-tax (Appeals) ?;