Interest on interest refund claims remanded for fresh examination after applying the Supreme Court's legal position.

Interest on the amount of refund interest already allowed under section 244(1) was considered in light of CIT v. Narendra Doshi, because the appellate order had not recorded a finding on the specific claim. The earlier section 154 application had been rejected, but the claim required fresh examination on the stated legal position. The matter was therefore remanded to the Assessing Officer for reconsideration after giving the assessee an opportunity of being heard.

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Issues: Whether the assessee was entitled to interest on the interest already allowed under section 244(1) of the Income-tax Act, 1961, and whether the matter required reconsideration by the Assessing Officer.

Analysis: The claim related to grant of interest on the amount of refund interest already allowed. The earlier application under section 154 had been rejected, and the appellate order did not return a finding on the specific claim for interest on interest. Reliance was placed on the Supreme Court decision in CIT v. Narendra Doshi, and the matter was required to be examined in that light after giving the assessee an opportunity of being heard.

Outcome: The issue was sent back to the Assessing Officer for fresh examination in accordance with the stated legal position.

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