Excess TDS refund follows nil-income reassessment, treating the refund as consequential relief rather than a fresh reassessment claim.

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....Excess TDS becomes refundable where reassessment proceedings initiated under section 148 accept the return and determine nil taxable income. Under section 237, tax paid in excess of tax properly chargeable must be refunded; no outstanding liability remains after such assessment. The refund is consequential to the reassessment rather than a fresh claim beyond its scope. The principle applies even where reassessment proceedings are dropped or culminate without additional taxable income, and the restriction on reopening concluded matters does not bar this consequential relief. Statutory interest on the excess TDS refund follows in accordance with law.....