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Revenue's Demand for Retroactive Interest u/s 220(2) Contradicts CBDT Circular and Section Mandate.

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....Levy of interest u/s 220(2) - Revenue demanded interest on the amount refunded to the Assessee - The demand for interest raised by the AO is contrary to the Circular issued by CBDT as well as the mandate of Section 220(2). The Section 220(2) does not empower the revenue to demand interest relating back to a set aside order, when a fresh assessment order has been passed thereafter. - HC....