Appeal Dismissed: No Interest on Interest Allowed by Tribunal

The Tribunal dismissed the appeal, upholding the Commissioner of Income-tax (Appeals) decision that the assessee was not entitled to interest on interest on the refund. The Tribunal relied on the Supreme Court judgment in CIT v. Gujarat Fluoro Chemicals [2013] 358 ITR 291 (SC), emphasizing that only the interest provided for under the statute could be claimed, and no additional interest on such statutory interest was payable.

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Issues Involved:
1. Non-granting of interest on interest on refund due to the assessee.
2. Applicability of the Supreme Court judgment in CIT v. Narendra Doshi [2002] 254 ITR 606 (SC).
3. Interpretation of statutory provisions related to interest on refunds under the Income-tax Act, specifically sections 240, 243, 244, and 244A.

Issue-wise Detailed Analysis:

1. Non-granting of Interest on Interest on Refund Due to the Assessee:
The primary grievance of the assessee was the non-granting of interest on interest on the refund due. The assessee cited the Supreme Court judgment in CIT v. Narendra Doshi [2002] 254 ITR 606 (SC) to support their claim. The facts of the case revealed that a refund of Rs. 3,97,399 was determined, but Rs. 1,18,092 was adjusted against a tax demand, which was later canceled. The assessee argued that the refund due was Rs. 3,58,726 with interest. The Assistant Commissioner computed the refund with interest from January 1, 1999, to March 19, 2010, but later withdrew excess interest for the period from January 1, 1999, to March 2002, amounting to Rs. 43,070. The Commissioner of Income-tax (Appeals) directed the Assessing Officer to refund the amount with interest but rejected the claim for interest on interest, citing the Supreme Court decision in CIT v. Gujarat Fluoro Chemicals [2013] 358 ITR 291 (SC).

2. Applicability of the Supreme Court Judgment in CIT v. Narendra Doshi [2002] 254 ITR 606 (SC):
The assessee contended that the judgment in CIT v. Narendra Doshi [2002] 254 ITR 606 (SC) supported their claim for interest on interest. The Tribunal noted that the judgment in Narendra Doshi was based on the principle that the Revenue was liable to pay interest on the amount of interest on advance tax, which it failed to pay. However, the Tribunal found that this judgment did not aid the assessee's claim for interest on interest under the given circumstances.

3. Interpretation of Statutory Provisions Related to Interest on Refunds:
The Tribunal examined the relevant statutory provisions, including sections 240, 243, 244, and 244A of the Income-tax Act. Section 240 mandates the refund of any amount due as a result of an appellate order. Section 243 provides for interest on delayed refunds, and section 244 deals with interest on refunds where no claim is needed. Section 244A, introduced with effect from April 1, 1989, provides for interest on refunds under various contingencies. The Tribunal noted that the assessee was refunded the excess tax paid along with interest under section 244A, and the calculation of interest was not disputed. The Tribunal concluded that the assessee was not entitled to interest on interest, as clarified by the Supreme Court in CIT v. Gujarat Fluoro Chemicals [2013] 358 ITR 291 (SC), which held that only the interest provided for under the statute could be claimed, and no other interest on such statutory interest was payable.

Conclusion:
The Tribunal dismissed the appeal filed by the assessee, upholding the order of the Commissioner of Income-tax (Appeals) and concluding that the assessee was not entitled to interest on interest on the refund. The Tribunal relied on the latest judgment of the Supreme Court in CIT v. Gujarat Fluoro Chemicals [2013] 358 ITR 291 (SC) to support its decision.

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