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Interest on delayed refunds starts from the Appellate Authority's order per Section 35FF, not application date per 11BB.
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....Interest on an asserted delay in disbursal of refund - the irresistible conclusion arrived at that interest on delayed refund is clearly dependent upon the making of a formal application as stipulated by Section 11B of the 1944 Act. - Section 35FF thus indicates that interest would commence from the date of the order of the Appellate Authority as distinct from the making of an application which is prescribed to be the starting point insofar as Section 11BB of the 1944 Act is concerned. - HC....