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Issues: Whether the respondents were liable to pay the balance interest on the delayed refund and, if so, up to what date.
Analysis: The Court recorded that the refund had already been received, but the balance interest remained unpaid. Taking note of the continuing delay, the Court fixed 1 March 2024 as the terminal date for calculation of interest and directed payment of the balance interest by that date, warning that non-compliance would amount to wilful disobedience and may invite contempt action.
Conclusion: The balance interest on the delayed refund was directed to be paid up to 1 March 2024, in favour of the assessee.
Final Conclusion: The petition was disposed of with a positive direction for payment of the balance interest within the time granted by the Court.
Ratio Decidendi: Where refund is belatedly paid, interest continues to run until the date fixed by the Court for actual payment, and failure to comply with such direction may attract contempt consequences.