2022 (1) TMI 1059

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....o set aside the impugned orders of Commissioner of Income Tax (Appeals) [hereinafter referred to as CIT(A)] dated 06.10.2020 & 21.10.2020 for A.Y. 2012-13 and 2013-14 respectively on identically worded grounds inter alia that; "1. On the facts and in the circumstances of the case and in law, the learned CIT(A) erred in confirming the order of the learned AO in not allowing the interest u/s. 244A in accordance with the provisions of the Act. 2. On the facts and in the circumstances of the case and in law, the learned CIT(A) erred in confirming the order of the learned AO in not allowing the interest u/s. 244A of the Act upto the date of issue of refund cheque in terms of binding CBDT circular No. 20D (XXII-22) dated 20.08.1....

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.... the light of the facts and circumstances of the case and case law relied upon. 7. Undisputedly, the Assessing Officer (in short 'AO') has granted interest of Rs. 11,25,66,651/- under section 244A of the Act vide order dated 20.02.2019 under section 250 of the Act read with order dated 31.05.2019 under section 154 of the Act for A.Y. 2012-13 and for A.Y. 2013-14, the AO granted interest on refund to the tune of Rs. 67,65,944/- under section 244A of the Act vide order dated 26.09.2018 read with order dated 31.05.2019 passed under section 154 of the Act. It is also not in dispute that AO has computed the interest under section 244A of the Act upto the date of signing of notice of the demand and not upto the date of issuance of refu....