Refund interest on cancelled wealth-tax assessment remains payable even after self-assessment adjustment and no surviving tax liability.

Interest on refund was payable where self-assessment tax under the Wealth-tax Act had been adjusted against an assessment demand that was later quashed, leaving no tax liability. The Tribunal treated section 34A(3A) as materially corresponding to section 244(1A) of the Income-tax Act and, following its earlier ruling, held that the refund remained eligible for interest even though no separate post-assessment recovery had been made. The excess amount became refundable once the assessment orders were cancelled, and the Revenue's appeal failed.

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Issues: Whether interest under section 34A(3A) of the Wealth-tax Act, 1957 is payable on refund where tax was paid by way of self-assessment under section 15B and the assessment demand was later quashed, leaving no tax liability.

Analysis: The assessee had paid amounts by self-assessment before the regular assessments. When the appellate authority quashed the assessment orders, the tax demands disappeared and the excess amounts became refundable. The Tribunal treated section 34A(3A) of the Wealth-tax Act, 1957 as materially corresponding to section 244(1A) of the Income-tax Act, 1961 and followed its earlier decision on the same point, holding that the refund arising from cancellation of the assessment remained eligible for interest notwithstanding that the payment had been adjusted against the assessed demand and no separate post-assessment recovery was made.

Conclusion: Interest on the refund was payable under section 34A(3A) of the Wealth-tax Act, 1957; the Revenue's appeal failed.

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