No Interest on Delayed Refund if Sanctioned Within Three Months Post-Commissioner's Order Dropping Demand.

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....Entitlement of Interest on delayed refund - relevant date for calculation of time - In the present case, refund arises only after passing of order-in-appeal by the Commissioner (Appeals) dropping the demand. Therefore, there is no occasion to give refund prior to the date of order-in-appeal. Considering that the refund was sanctioned within three months from the date of application and the refund arose consequent to order of Commissioner (Appeals), no interest is payable from the date of deposit of the duty during investigation. - AT....