Interest on delayed refund must be reckoned from the original...

Interest on delayed refund must be reckoned from the original refund application date where the earlier refusal to process that application was found illegal and set aside. The later refiled application, prompted only by the authority's unlawful action, cannot be treated as the starting point to defeat interest otherwise payable. The impugned orders were set aside to the extent they denied interest, and the claim was directed to be decided by taking the date of the initial application into account.