Interest on refund under transitional provisions denied where refund was paid within the statutory time limit.

Where an assessment completed under the earlier Act gave rise to a refund only after commencement of the new Act, the transitional refund provisions of the new Act governed the claim for interest. Because the refund was made within the statutory six-month period after the order directing payment, the condition for liability to pay interest was not met, and no interest was payable on the refund.

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Issues: Whether interest on refund was payable under the provisions governing refunds and interest where the assessment had been completed before commencement of the new Act, but the refund became due only after such commencement.

Analysis: The assessment was completed under the earlier Act, and the refund arose only because of the Supreme Court's later decision and the consequential order. On those facts, the transitional provision applied, and the scheme of the new Act governing interest on refunds controlled the claim. Since the refund had been made within six months of the order directing it, the statutory condition for liability to pay interest was not satisfied.

Conclusion: The claim for interest on refund was not allowable and was correctly rejected.

Ratio Decidendi: Where an assessment completed before commencement of the new Act gives rise to a refund only after such commencement, the claim for interest on that refund is governed by the transitional and refund provisions of the new Act, and no interest is payable if the refund is made within the statutory time limit.

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