Simple interest under section 244(1A) does not extend to interest on interest for tax refunds.

Section 244(1A) was construed on its plain language as allowing simple interest only on the refundable excess amount from the relevant date until refund is granted. The provision was treated as materially different from section 214(1), so reasoning under section 214 could not be used to claim compound interest or "interest on interest" under section 244(1A). On that construction, the assessee was not entitled to interest on interest, and the appeal was rejected.

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Issues: Whether the assessee was entitled to "interest on interest" on the refund amount under section 244(1A) of the Income-tax Act, 1961.

Analysis: Section 244(1A) was construed on its plain language as providing for simple interest at the prescribed rate on the amount found to be in excess and refundable, from the relevant date until the refund is granted. The provision was held to be materially different from section 214(1), and the reasoning applied to section 214 could not be extended to claim compound interest or "interest on interest" under section 244(1A). On that construction, no substantial question of law arose.

Conclusion: The assessee was not entitled to interest on interest under section 244(1A), and the appeal was rejected.

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