2025 (7) TMI 516

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....d together and disposed of by this common order. 3. For the sake of convenience and clarity the facts relevant to the appeal bearing ITA No. 529/Coch/2023 for AY 2000-01 are stated herein. 4. Brief facts of the case are that the appellant is a private scheduled bank. The return of income for AY 2000-01 was filed on 28.11.2000 declaring income of Rs. 2,30,87,400/- and the same was revised at an income of Rs. 2,61,44,880/-. Subsequently, reassessment was completed vide order dated 31.01.2003 passed u/s. 143(3) r.w.s. 147 of the Income Tax Act, 1961 (the Act) at a total income of Rs. 1,63,03,51,760/-. The said order was appealed against before the CIT(A), who vide order dated 04.03.2004 partly allowed the appeal. On further appeal before....

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.... the appellant is not entitled for interest on interest. 7. Being aggrieved, the appellant is in appeal before this Tribunal in the present appeal. 8. The learned counsel for the assessee submitted that the appellant is entitled for interest u/s. 244A of the Act even on interest granted u/s. 244A of the Act. In support of this he placed reliance on the following decisions: - i) Union of India v. Tata Chemicals Ltd. [2014] 363 ITR 658 ii) Union Bank of India v. ACIT [2016] 52 ITR(T) 221 (Mum) iii) Tata Sons (P.) Ltd. v. DCIT [2024] 204 ITD 802 (Mum) 9. On the other hand, the CIT-DR submits that the order passed by the CIT(A) is in consonance with the law laid down by the Hon'ble Apex Court in the case ....