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56 Tata Sons Pvt. Ltd. vs. DCIT
ITA No.: 2362 / Mum / 2023
A.Y.: 1993–94
Date of Order: 6th December, 2023
Section: 244A
Interest under section 244A is to be calculated by first adjusting the amount of refund already granted towards the interest component and balance left, if any, should be adjusted towards the tax component.
FACTS
The return of income of the assessee for A.Y. 1993–94 was filed on 31st December, 1993, returning NIL income.
The return was subject to assessment / re-assessment and rectification over a period of time.
Tribunal, through orders dated 4th February, 2015, and 1st January, 2016, gave relief to the assessee.
The AO passed an order giving effect (OGE) dated 8th March, 2016, granting the refund of ₹30,45,62,594, and the assessee received the said refund on 18th August, 2022.
Aggrieved by the short credit of interest on refund, the assessee filed an appeal before CIT(A) / NFAC.
