Refund interest under section 244A runs until actual payment when the Revenue delays issuance beyond determination.

Interest on refund under section 244A accrues until the refund is actually issued where the Revenue retains the excess tax beyond the date of determination in the section 143(1) intimation. The return was later accepted in scrutiny under section 143(3), and the refund was granted only thereafter, so the terminal point for interest was the month of actual refund payment. The assessee was therefore entitled to interest up to that date, and the direction to grant such interest was in the assessee's favour.

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Issues: Whether the assessee was entitled to interest on refund under section 244A of the Income-tax Act, 1961 up to the date on which the refund was actually granted, and not merely up to the date of determination of refund in the intimation under section 143(1).

Analysis: The return was processed under section 143(1), but the subsequent scrutiny assessment under section 143(3) accepted the assessee's position in substance and the refund was in fact issued much later than the date adopted for computing interest. Since section 244A grants interest on excess tax refunded for the period during which the Revenue retained the money, the relevant terminal point for interest is the actual payment of refund where the refund is delayed beyond the date of determination.

Conclusion: The assessee was entitled to interest under section 244A up to the month in which the refund was actually issued, and the direction to the Assessing Officer to grant such interest was in favour of the assessee.

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