Pre-deposit refund interest runs from the Tribunal's final order when assessment is concluded and no stay exists.

Interest on refund of pre-deposit was payable from the date the Tribunal's order finally fixed the assessable value, because only duty quantification remained before the original authority. In the absence of any stay from the Supreme Court, the assessment attained finality on the Tribunal's order itself and the refund should have followed in the ordinary course from that date. Board circulars were consistent with interest becoming payable once the matter stood finally concluded at the Tribunal stage. The Revenue's contention that interest should run only from the later dismissal of its appeal by the Supreme Court was rejected.

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Issues: Whether interest on the refund of pre-deposit was payable from the date of the Tribunal's order finalising the assessment, or only from the date of dismissal of the Revenue's appeal by the Supreme Court.

Analysis: The Tribunal held that its earlier order had clearly fixed the assessable value and left only quantification of duty to the original authority. In the absence of any stay by the Supreme Court, the assessment attained finality on the Tribunal's order itself and the pre-deposit ought to have been refunded in the normal course from that date. The Board's circulars also supported payment of interest on pre-deposits once the matter stood finally concluded at the Tribunal stage.

Conclusion: Interest on the refunded pre-deposit was payable from the date of the Tribunal's order, not from the date of the Supreme Court's dismissal of the Revenue's appeal, and the Revenue's challenge was rejected.

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