Legal and Practical Implications of Charging Interest on Excess Refunds under the Income Tax Regime : Clause 426 of the Income Tax Bill, 2025 Vs. Section 234D of the Income-tax Act, 1961

Interest on excess refunds: Bill imposes interest from refund grant to regular assessment, with reduction if appellate orders confirm refund.

Clause 426 charges simple interest on refunds granted under section 270(1) that exceed amounts determined on regular assessment, with interest computed from the date of grant to the date of regular assessment. Assessments under section 279 are deemed 'regular assessment' for this purpose. Interest is reduced where appellate or revisionary orders ultimately validate the refund in whole or part. The clause mirrors Section 234D's core mechanics but changes cross-references and lacks an explicit retrospective application, raising transitional and interpretational concerns.