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Issues: Whether the petitioner is entitled to interest under Section 244A of the Income-tax Act, 1961 beyond the date of intimation under Section 143(1) - specifically interest up to the date of credit to the petitioner's bank account, and whether the Assessing Officer is to be directed to grant such interest by passing a manual order and uploading it on the ITBA portal so CPC may release the refund.
Analysis: The petitioner had received the refund intimated under Section 143(1) but interest was paid only up to the date of that intimation. The petitioner seeks interest up to the date of actual credit to its bank account (a further period). The revenue/CPC has indicated that the functionality to grant interest for the intervening period is under development at CPC and that the Assessing Officer can grant the required interest by passing a manual order and uploading the order on the ITBA portal, following which CPC will issue the refund.
Conclusion: The Assessing Officer is directed to grant interest under Section 244A of the Income-tax Act, 1961 by passing a manual order and, upon uploading the order on the ITBA portal, the refund due shall be issued by CPC within six weeks. This direction is in favour of the assessee.
Ratio Decidendi: Where statutory interest under Section 244A is due beyond the date of intimation under Section 143(1) but automated CPC functionality is unavailable, the Assessing Officer must grant such interest by a manual order and upload it on the ITBA portal to enable CPC to release the refund.
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