Refund interest adjustment: Refund to adjust interest first, then principal. Fair methodology.

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Full Text of the Document

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....When calculating interest u/s 244A(1), if a refund is granted earlier, it should be adjusted against the interest component first, and the remaining amount, if any, should be adjusted against the principal refund amount. This follows the same methodology as when part taxes are paid by the assessee, where it is first adjusted against the interest payable and then against the tax due. The CIT(A) rightly directed the Assessing Officer to examine the computation of refund, including interest u/s 244A. The impugned order is upheld, and the appeal is dismissed.....