Wealth-tax refund interest applies even without a demand notice where excess payment is refunded under the Act.

Interest on wealth-tax refunds was discussed in relation to Section 34A(4B)(a) of the Wealth-Tax Act, 1957. The provision grants simple interest when a refund becomes due under the Act, and the Explanation fixes the date for computation rather than restricting the right to interest. A refund under Section 16(1)(ii) may arise from acceptance of excess payment even without a notice of demand under Section 30, so entitlement to interest cannot be confined to cases where such notice was issued. The assessee was therefore entitled to interest on the refund.

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Issues: Whether an assessee who filed a return on self-assessment and later obtained refund of wealth-tax was entitled to interest under Section 34A(4B)(a) of the Wealth-Tax Act, 1957, and whether the entitlement depended on issuance of a notice of demand under Section 30.

Analysis: The statutory scheme provided for processing of returns, intimation of tax or refund, regular assessment, and refunds. Section 34A(4B)(a) granted simple interest where refund became due to the assessee under the Act. The Explanation referred to the date from which interest was to be computed and could not be read as limiting the right to interest only to cases where a notice of demand under Section 30 had been issued. A refund under Section 16(1)(ii) could arise on acceptance of excess payment even without a demand notice, and the benefit of interest could not be denied by a narrow construction of the provision.

Conclusion: The assessee was entitled to interest on the refund, and the contention that such interest was payable only where a notice of demand had been issued was rejected.

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