Section 50 interest demand fails where transitional credit is later treated as refundable and already adjusted against tax liability.

Interest under section 50 was not exigible where the amount earlier treated as transitional credit was later ed as refundable and had already been adjusted against tax liability. Once the respondent passed a subsequent order treating the amount as excess and liable to refund, the factual basis for any interest demand ceased to exist. On those facts, no further demand on that basis could survive and the writ petition was closed.

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Issues: Whether interest under section 50 could be demanded when the amount earlier treated as transitional credit had subsequently been accepted as refundable and had already been adjusted against tax liability.

Analysis: The respondent subsequently passed an order accepting that the amount was excess and liable to be refunded to the petitioner. Since the petitioner had already adjusted the amount against its tax liability, the basis for demanding interest under section 50 no longer survived. In view of the later order, the writ petition required closure.

Conclusion: Interest under section 50 was held not to arise on the facts, and no further demand on that basis was sustained.

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