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ITAT ruled that taxpayer is entitled to interest on refund arising from excess self-assessment tax u/s 244A(1)(b), despite the specific provision 244A(1)(aa) being introduced later by Finance Act 2016. The amendment was clarificatory in nature, not restrictive. Due to 68-month delay in refund processing (December 2014 to July 2020), ITAT granted additional interest @3% per annum u/s 244A(1A), but only from June 1, 2016 (effective date of amendment) until refund date. This aligns with precedent set in Stock Holding Corporation case and Nima Specific Family Trust ruling. Taxpayer's appeal for additional interest partially allowed; revenue's appeal dismissed.
ITAT ruled that taxpayer is entitled to interest on refund arising from excess self-assessment tax u/s 244A(1)(b), despite the specific provision 244A(1)(aa) being introduced later by Finance Act 2016. The amendment was clarificatory in nature, not restrictive. Due to 68-month delay in refund processing (December 2014 to July 2020), ITAT granted additional interest @3% per annum u/s 244A(1A), but only from June 1, 2016 (effective date of amendment) until refund date. This aligns with precedent set in Stock Holding Corporation case and Nima Specific Family Trust ruling. Taxpayer's appeal for additional interest partially allowed; revenue's appeal dismissed.
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