Transitional refund interest under the Income-tax Act, 1961 was unavailable because the claim did not satisfy section 243.

Refund interest claims arising from assessments completed before the Income-tax Act, 1961 are governed by the transitional scheme in section 297(2)(i), not by section 66(7) of the Indian Income-tax Act, 1922. On the stated facts, the 1961 Act did not allow interest on the refund unless the case fell within section 243, and the assessee's claim did not satisfy that provision. The assessee was therefore not entitled to interest on the refund, and the appeal failed.

---

---

Issues: Whether the assessee was entitled to claim interest on the refund arising from the earlier assessment, and whether the claim was governed by section 297(2)(i) of the Income-tax Act, 1961 rather than section 66(7) of the Indian Income-tax Act, 1922.

Analysis: The assessment had been completed before the Income-tax Act, 1961 came into force, so the matter fell within the transitional scheme of section 297(2)(i) of the Income-tax Act, 1961 and not under section 66(7) of the Indian Income-tax Act, 1922. The new Act did not provide for payment of interest unless the case came within section 243 of the Income-tax Act, 1961. The assessee's claim did not satisfy section 243.

Conclusion: The assessee was not entitled to interest on the refund, and the appeal failed.

---