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of The HC allowed the appeal by the revenue, set aside the tribunal's order and held that the refund crystallized only on 05.09.2023 upon the reassessment order. Consequently the respondent is not entitled to interest from any date anterior to the Section 27(1) refund application (05.08.2022) or from 11.01.2011, since Section 27A permits interest only after three months from receipt of a valid refund application and an order quantifying refund; shifting the interest commencement date earlier would impermissibly rewrite Sections 27/27A. The HC rejected the respondent's contention for rectification of the 12 shipping bills and found no clerical or arithmetical mistake warranting reassessment under Section 154. Appeal allowed.
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