DCIT-14(1)(1), MUMBAI vs. INDIAN OIL CORPORATION LTD, MUMBAI

ITA 2752/MUM/2024Status: DisposedITAT Mumbai31 December 2024AY 2009-10Bench: the amendment of section 244 by Finance Act, 2016. 3) The appellant prays that the order of the CIT(A) on the above grounds be set aside and that of the Assessing Officer be restored. 4) The appellant craves leave to amend, or alter any grounds or add a new ground, which may be necessary.” Page 31 pages
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What did the Tribunal hold?

The Tribunal held that interest on excess self-assessment tax is allowable under Section 244A(1)(b) even for periods prior to the amendment. For delayed refunds, additional interest is allowable only from the date of introduction of the relevant provision (01.06.2016).

What were the facts?

The assessee claimed interest on excess self-assessment tax and additional interest for delayed refund processing. The Assessing Officer denied these claims, citing amendments to Section 244A of the Income Tax Act. The CIT(A) initially dismissed the appeal but was later directed to adjudicate de novo.

What were the issues?

Whether interest on excess self-assessment tax is allowable for assessment years prior to the amendment of Section 244A, and whether additional interest for delayed refund processing is applicable for periods before the introduction of Section 244A(1A).

Which sections of the Income-tax Act were involved?

Section 244A,Section 153

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Before: SHRI ANIKESH BANERJEE & SMT. RENU JAUHRI

For Appellant: Shri. Niraj D. Sheth
For Respondent: Shri Krishna Kumar
Hearing: 12.11.2024Pronounced: 31.12.2024

PER RENU JAUHRI [A.M.] :- These cross appeals are filed by the assessee and the revenue against the order of the Learned Commissioner of Income-tax (Appeals), Mumbai/National Faceless Appeal Centre, Delhi [hereinafter referred to as “CIT(A)”] dated 21.03.2024 passed u/s. 250 of the Income-tax Act, 1961 [hereinafter referred to as “

The order continues below.

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