S.220(2) of the Actis not included in the category of “orders appealable” under S. 246A . Without making a challenge to the tax liability itself, the levy of interest independently cannot be challenged before the Commissioner (A).( AY. 1991 -92 )
S. Appaswamy. v. DCIT (2019) 416 ITR 42/ 311 CTR 650/ 183 DTR 399 (Mad) (HC)
S. 246A : Appeal – Commissioner (Appeals) – Appealable orders – levy of interest – Appeal is not maintainable unless tax liability is challenged .[ S.220 (2) ]