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of <h1>Tribunal Decides on Interest Allowance and Charges for Tax Refund</h1> <h3>Dy DIT (IT)-1(2) Versus M/s THE DEVELOPMENT BANK OF SINGAPORE LTD</h3> Dy DIT (IT)-1(2) Versus M/s THE DEVELOPMENT BANK OF SINGAPORE LTD - TMI Issues:1. Allowance of interest u/s.244A on self-assessment tax refund.2. Chargeability of interest u/s.234D for A.Y. 2001-02.3. Claim of interest on interest u/s.244A for delayed refund.Analysis:1. *Allowance of interest u/s.244A on self-assessment tax refund:*The case involved a dispute regarding the allowance of interest u/s.244A on self-assessment tax refund. The Revenue contended that interest should not be paid on self-assessment tax, but the CIT(A) allowed it based on precedents. The Tribunal upheld the CIT(A)'s decision, citing judgments from various High Courts and the Mumbai Bench of Tribunal. The Tribunal found the decision in line with previous rulings and dismissed the Revenue's appeal.2. *Chargeability of interest u/s.234D for A.Y. 2001-02:*The issue of chargeability of interest u/s.234D for A.Y. 2001-02 was raised. The Tribunal noted that a Special Bench decision had clarified that no interest could be charged u/s.234D for the mentioned assessment year. Relying on this precedent, the Tribunal decided against the Revenue on this issue and dismissed their appeal.3. *Claim of interest on interest u/s.244A for delayed refund:*The assessee claimed interest on interest u/s.244A for a delayed refund, citing the Supreme Court's decision in Sandvik Asia Ltd. vs. CIT. The CIT(A) had rejected this claim, stating no provision allowed for such interest. However, the Tribunal sided with the assessee, emphasizing the wrongful retention of the refund by the Revenue. Citing the Sandvik Asia Ltd. case, the Tribunal directed the AO to allow interest on interest, partially allowing the assessee's appeal.In conclusion, the Tribunal addressed the issues of interest on self-assessment tax refund, interest chargeability u/s.234D, and interest on interest for delayed refunds, providing detailed analysis and legal interpretations to resolve the disputes effectively.
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