Court orders interest on full refund amount, emphasizing timely payment and adherence to directives.

The appeal was allowed in favor of Tien Yuan India P. Ltd., directing the grant of interest on the entire amount of Rs. 2 crores refunded to them. The High Court ordered interest to be paid on the full sum from 04.01.2007 onwards until 27.04.2015, emphasizing that adjustments for redemption fine and demand confirmation should only be made after granting interest on the complete Rs. 2 crores. The Tribunal upheld the importance of following the High Court's directive, ensuring that the appellants receive the entitled interest on the total refund amount.

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Issues:
Denial of interest on refund sanctioned to Tien Yuan India P. Ltd.

Analysis:
The appeal was filed by Tien Yuan India P. Ltd. against the denial of interest on a refund sanctioned to them. The appellants had deposited Rs. 2 crores during an investigation related to the availment of cenvat credit. A demand of Rs. 22,13,22,732/- was confirmed by the Commissioner, out of which Rs. 2 crores were appropriated towards confirmation of cenvat credit. The Tribunal confirmed a demand of Rs. 3,93,778,240/- against the appellants' unit in Jammu but set aside the demand of Rs. 22,13,22,732/-. The Tribunal also confirmed certain amounts against the appellants and upheld the confiscation of goods and imposition of redemption fine. The appellants filed a refund of Rs. 2 crores along with interest, but the revenue ordered a refund of the net amount after adjusting the demand confirmation and redemption fine. The interest was paid only on the net amount sanctioned, not on the full Rs. 2 crores. The appellants sought interest on the entire Rs. 2 crores and challenged the grant of interest only on the net value after adjustments. The High Court directed that interest should be granted on the entire Rs. 2 crores. The Tribunal, after considering the submissions, held that the appellants were entitled to interest on the entire amount of Rs. 2 crores from 04.01.2007 onwards till 27.04.2015, as per the High Court order. The adjustment of redemption fine and confirmation demand could only be done after calculating and granting interest on the full Rs. 2 crores. Consequently, the appeal was allowed.

This judgment highlights the importance of granting interest on the full amount of refund sanctioned, as directed by the High Court. It clarifies that interest should be calculated on the entire sum deposited by the appellants, and adjustments can be made only after interest on the full amount is granted. The Tribunal's decision emphasizes adherence to the High Court's order and ensuring that the appellants receive their entitled interest on the entire refund amount.

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