Refund interest under Vivad se Vishwas: section 244A exclusion does not bar reasonable interest for Revenue-caused delay.

The Direct Tax Vivad se Vishwas Act, 2020 requires payment within fifteen days of the certificate and implies a corresponding obligation to refund any excess amount within a reasonable time. Section 7 excludes statutory refund interest under section 244A of the Income-tax Act, but that exclusion does not necessarily prevent interest where refund delay is attributable to the Revenue. In such cases, reasonable interest may still be awarded under sections 3 and 4 of the Interest Act, 1978 for unjustified retention of the assessee's money.

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Issues: Whether, on a refund arising from proceedings under the Direct Tax Vivad se Vishwas Act, 2020, the assessee was entitled to interest despite the exclusion of section 244A of the Income-tax Act, 1961 in section 7 of the 2020 Act.

Analysis: Section 5 of the 2020 Act required the declarant to pay the determined amount within fifteen days of receipt of the certificate, and the Court held that this statutory structure also implied a corresponding obligation on the Department to process and refund any excess amount within a reasonable time. Section 7 barred refund interest under section 244A in the ordinary statutory sense, but it did not create an absolute prohibition against interest where the delay in refund was attributable to the Revenue. The Court further held that, independent of the Income-tax Act and the 2020 Act, reasonable interest could be granted under sections 3 and 4 of the Interest Act, 1978 when the State unjustifiably retained the assessee's money.

Conclusion: The assessee was entitled to interest on the delayed refund, and the Revenue's challenge to the grant of interest failed.

Ratio Decidendi: An express exclusion of statutory refund interest does not bar a court from awarding reasonable interest for unjustified delay in refund where the delay is attributable to the Revenue and the money has been retained without right.

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