Refund of investigation deposit carries 12% interest where payment was made under mistaken liability and proceedings were dropped.

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....An amount paid during investigation was treated as a refundable deposit, not a voluntary duty payment, because the assessee had consistently disputed liability and the payment was made under a mistaken impression at the insistence of Revenue. Once the proceedings were dropped, the Tribunal held that refund of the investigation deposit carried interest as a matter of course. Applying its earlier authorities, it further held that interest was payable at 12% from the date of deposit until refund, and the denial of interest was set aside.....