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In this case, the assessment year involved is 1970-71 for which the corresponding accounting period is the year ending on March 31, 1970.

The facts as found by the Tribunal are as under :

The assessee, an employer-company, has six expatriate (contract) employees during the financial year in question to whom the company paid certain tax-free salaries including tax-free perquisites on account of rent-free quarters. It has been stated by the employer that, in accordance with the approval of the Board, these employees were enjoying tax-free salaries and perquisites, but the employer had to pay tax on such amount of tax-free salary and perquisites. From the statement filed by the employer-company on February 27, 1979, it appeared that the company deposited Rs. 11,29,918 towards tax due on the salary and perquisites in respect of the contract staff on different dates. This statement, however, revealed that, although these deposits were made by the employer-company on a monthly basis, yet the quantum of deposits had not been uniform throughout the year. Particularly, for the months of February and March, 1971, the deposits on account of contract staff were Rs. 1,69,760 and Rs. 7,54,760, respectively. It further transpired that the employer-company paid the net amount of salary to the contract staff at a uniform monthly rate, but the deposit of the tax on account of this salary had not been uniform, particularly, in the last two months of the financial year as mentioned above. Obviously, therefore, the employer had failed to comply with the relevant provisions of sections 192 and 200 read with the relevant provisions of the rules thereunder. Thus, the default and irregularities on the part of the employer-company attracted the provisions of section 201 (1A) of the Act. The Income-tax Officer, after allowing the assessee an opportunity of being heard and rejecting the explanation offered by the assessee, charged interest of Rs. 28,471 under section 201 (1A) on March 31, 1976. That order was set aside by the Tribunal by its order dated August 30, 1978 in Income-tax Appeal No. 1167/(Cal) of 1977-78 with a direction for remaking a self-contained order. Consequently, the Income-tax Officer passed the order under section 201 (1A) again on June 1, 1979, charging interest of Rs. 46,008.47.