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of Interest on the refund u/s 27A - the Explanation to Section 27A makes it clear that the orders passed by the Commissioner (Appeals) and the Appellate Tribunal are also deemed to be orders passed u/s 27(2) - even if the ACC rejects an application for refund u/s 27(2), the moment the said order is set aside on first appeal or second appeal, the order merges - assessee is entitled to interest from the date of expiry of 3 months of the date of application
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