Interest on delayed refund runs only from a valid rectified application, not from a defective refund filing.

A defective refund application does not create a valid claim in law, so no enforceable right to interest on delayed refund arises from the original filing. Interest is computed only from the date a proper, rectified refund application is received by the Department, because the defects must first be removed and a valid claim must come on record within limitation. The assessee's claim for interest from the date of the defective application was rejected.

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Issues: Whether interest on delayed refund is payable from the date of filing of a defective refund application or only from the date on which the defects are rectified and a valid application comes on record.

Analysis: A defective refund claim does not acquire the character of a valid claim in law. Until the defects are removed and a proper application is filed within limitation, no enforceable right to interest on delayed refund arises from the original defective filing. The relevant date for computing interest is the date on which the valid refund application is received by the Department.

Conclusion: Interest on delayed refund is payable only from the date of filing of the rectified valid application, not from the date of the defective application; the assessee's claim was rejected.

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