B. L. Hansaria, J — The question involved in this writ petition is relatable to the payment of interest by the Government under section 214 of the Income-tax Act, 1961, hereinafter the Act. Under that provision of law interest is payable by the Government at the stipulated rate on the amount by which the aggregate sum of any instalments of advance tax paid during any financial year in which they are payable under sections 207 to 213 exceeds the amount of tax determined on regular assessment. The question for decision is if the advance tax had not been paid on the dates specified for this purpose but had been paid during the entire financial year whether on the excess amount interest would be payable by the Government? A similar question, of course, relatable to section 215 of the Act, dealing with interest payable by the assessee, was examined by this Court is Sockerating Tea Co. vs. CIT, (1988) 2 GLR 231 and it was held that the payments within the financial year after the due dates should not be excluded as payments are made towards tax liability covering the financial year. 2. Shri Choudhury however submits that the same ratio would not apply in case of interest payable by the Government under section 214 because section 211 of the Act has laid down the dates by which advance tax has to be paid in instalments. In this connection he has also referred to Kangundi Industrial Works vs. ITO, 121 ITR 339 a decision of the Andhra Pradesh High Court and to A. Sethmnadhavan vs. CIT, 122 ITR 587 (Kerala) which have taken the view as put forward by Shri Choudhury. 3. Shri Goswami, however, brings to our notice the decision's of other High Courts which have stated that if the instalments of advance tax have been paid during the financial year and if the aggregate of the instalments exceeds the amount of tax determined on regular assessment interest becomes payable even if the advance tax had not been paid on the dates stipulated by section 211 of the Act. It was pointed out in this connection that section 214 (1) 6f the Act has not referred to the dates'' on which the instalments are payable. It was pointed out in this connection that section 214 (1) 6f the Act has not referred to the dates'' on which the instalments are payable. It has been emphasised in these decision that section 214 of the Act only states that instalment must have been paid during the financial year in which they are payable. It was further pointed out that though section 214 refers to instalments payable under sections 207 to 213 but there is no reference in section 214 about the manner of payment of instalments. It was therefore concluded that it was not permissible to read more in section 214 than what is expressly stated. This is the view expressed in CIT vs. S. N. K. Trust, 144 ITR 526 (MP). From the decision in this case we find that similar view had been taken by the Gujarat High Court in Chandrakonta vs. ITO, 123 ITR748. It was further pointed out in this decision that under section 215 to 217 an assessee is made liable to pay interest whenever amount on advance tax falls short of certain percentage. So, it was held that the same yardstick should apply against the revenue. Other decisions referred in the connection by Shri Goswami are those reported in Commissioner of Income-tax vs. Traub (India) Pvt. Ltd., 118 ITR 525 (Bombay) and Commissioner of Income-tax vs. T. T. Investments and Traders Pvt. Ltd., 148 ITR 347 {Madras). As the same view has been taken by this Court in Sockerating, we find no good reason to depart from the same. 4. The petition is therefore disposed of by stating that interest would be payable by the Government on excess advance tax even if the tax had not been paid on the due date but had been paid during the financial year. The order of the Commissioner by which he refused to pay interest under section 214 is therefore set aside and the department is directed to pay interest in the light of the observation made above.