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of The HC affirmed that despite no express provision in the Direct Tax Vivad se Vishwas Act, 2020, the Revenue is obligated to refund excess amounts within reasonable time following acceptance of declaration. In this case, the ACIT unreasonably delayed refund action from December 2021 until November 2023. The court determined it has authority to grant interest under Section 3 of the Interest Act, 1978, notwithstanding provisions in the Income Tax Act or the Vivad se Vishwas Act, when delay is solely attributable to Revenue's fault. Concurring with precedent that the State must compensate for wrongfully retaining and using funds, the HC upheld the Single Judge's decision ordering interest payment on the delayed refund amount.
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