CIT v. HEG Ltd.

324 ITR 331Supreme Court of India2010#1807 most cited

What is CIT v. HEG Ltd. authority for?

Under Section 244A, the "amount due" for a refund includes both the principal tax and the interest accrued thereon up to the date the refund is granted. If the revenue fails to pay the full amount of refund, it is liable to pay further interest on the outstanding balance of this total refund, which does not constitute "interest on interest".

63

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2012 to 2026.

Also referred to as

CIT v HEG Ltd · 324 ITR 331 · Section 244A · interest on refund · interest on interest · Section 244A(1) · calculation of interest · unpaid refund balance · accrued interest · Income Tax Act · Supreme Court

Also reported as

189 Taxmann 335

Sections most often in play

Section 244ASection 154Section 143(3)Section 244A(1A)Section 147Section 243Section 244Section 244(1A)

Issues it is cited on

section 140a(1)interest on interestsection 244a(1)section 140ainterest on refundsection 244section 243section 244asection 140advance taxsection 24section 206c

Judgments citing CIT v. HEG Ltd.

Dcti-3(4), Mumbai vs. M/S Idbi Bank Ltd, Mumbai

Accordingly, the grounds raised assessee are allowed and that of the revenue are dismissed

ITA 2080/MUM/2023[1997-98]Status: DisposedITAT Mumbai30 Oct 2023AY 1997-98

Bench: Shri Vikas Awasthy () & Ms. Padmavathy S. ()

Section 143(3)Section 244A

…tilizer Co-operative (2016) 71 taxmann.com 37 (Delhi), where it is held that the ruling of the Supreme Court in the case of CIT vs. Gujarat Flouro Chemicals Ltd (supra), should be followed as opposed to the ratio laid down in the case of CIT vs HEG Ltd (2010) 324 ITR 331 which has been followed in the decision of the coordinate bench in the case of Bank of Baroda (supra). Accordingly, the Ld.DR submitted that the decision of the co-ordinate bench cannot be applied in assessee’s case since there is a ratio laid down by the higher court that there cannot be any interest on interest on refunds granted to the assesse…

DCIT, Cir-3(3)(1), Mumbai vs. Sicom Limited, Mumbai City

In the result, the appeal filed by the revenue is dismissed

ITA 2034/MUM/2023[1999-2000]Status: DisposedITAT Mumbai16 Oct 2023AY 1999-2000

Bench: Shri Pavan Kumar Gadale & Shri Gagan Goyalita Nos. 2034 & 2035/Mum/2023 (A.Y:1999-2000 &1998-99) Dcit, Circle-3(3)(1), Vs. M/S Sicom Limited, Room No.609, Solitaire Corporate Aayakar Bhavan, Park, Building No.4, M.K. Road, Guru Nanak Marg, Mumbai-400020. Chakala, Midc S.O, Mumbai-400093. Pan/Gir No. : Aaacs5524J Appellant .. Respondent

Section 143(3)Section 21Section 244ASection 244A(1)

…f any shall be adjusted towards the tax component. Thus, with these directions, the appeal of the assessee is allowed. 1.. Reliance is also placed on the following decisions: ITA.No.2034&2035/Mum/2023 CO.No72&73/Mum/2023. M/s. Sicom Ltd. Mumbai. HEG Ltd. (324 ITR 331) (SC) Bank of Baroda (ITA No. 1646/M/2017)IMENT! Trib) Peerless General Finance and Investment Co. Ltd (57 ITR(T) 536) (Kol) 1. Following the above judicial precedents and methodology stated in Explanation 1 to section 140A, the refund already issued to the Appellant shall first be adjusted against the interest and then towards the principal a…

ACIT-2(2)(1), Mumbai vs. State Bank of India, Mumbai

In the result, the appeal of the revenue is dismissed

ITA 1102/MUM/2023[2013-14]Status: DisposedITAT Mumbai27 Jun 2023AY 2013-14

Bench: Shri B.R. Baskaran & Shri Rahul Chaudhary

For Appellant: Shri Ketan VedFor Respondent: Shri Paresh Deshpande
Section 140ASection 244A

…interest on the balance amount due from the department to the assessee, on a particular date, does not amount to payment of interest on interest. Their lordships, taking support from the judgment of Hon'ble Supreme Court in the case of CIT v. HEG Ltd. [2010] 324 ITR 331/189 Taxman 335, observed as under: '14. Matter was taken by the Revenue before the Supreme Court in the case of HEG Limited and the SLP was granted and civil appeal was registered. The Supreme Court thereupon answered the question against the Revenue in the following words:- Therefore, this is not a case where the assessee is claiming compound in…

ACIT-2(2)(1), Mumbai vs. State Bank of India, Mumbai

In the result, the appeal of the revenue is dismissed

ITA 1101/MUM/2023[2012-13]Status: DisposedITAT Mumbai27 Jun 2023AY 2012-13

Bench: Shri B.R. Baskaran & Shri Rahul Chaudhary

For Appellant: Shri Ketan VedFor Respondent: Shri Paresh Deshpande
Section 140ASection 244A

…interest on the balance amount due from the department to the assessee, on a particular date, does not amount to payment of interest on interest. Their lordships, taking support from the judgment of Hon'ble Supreme Court in the case of CIT v. HEG Ltd. [2010] 324 ITR 331/189 Taxman 335, observed as under: '14. Matter was taken by the Revenue before the Supreme Court in the case of HEG Limited and the SLP was granted and civil appeal was registered. The Supreme Court thereupon answered the question against the Revenue in the following words:- Therefore, this is not a case where the assessee is claiming compound in…

ACIT-2(2)(1), Mumbai vs. State Bank of India, Mumbai

In the result, the appeal of the revenue is dismissed

ITA 1100/MUM/2023[2009-10]Status: DisposedITAT Mumbai27 Jun 2023AY 2009-10

Bench: Shri B.R. Baskaran & Shri Rahul Chaudhary

For Appellant: Shri Ketan VedFor Respondent: Shri Paresh Deshpande
Section 140ASection 244A

…interest on the balance amount due from the department to the assessee, on a particular date, does not amount to payment of interest on interest. Their lordships, taking support from the judgment of Hon'ble Supreme Court in the case of CIT v. HEG Ltd. [2010] 324 ITR 331/189 Taxman 335, observed as under: '14. Matter was taken by the Revenue before the Supreme Court in the case of HEG Limited and the SLP was granted and civil appeal was registered. The Supreme Court thereupon answered the question against the Revenue in the following words:- Therefore, this is not a case where the assessee is claiming compound in…

ACIT-2(2)(1), Mumbai vs. State Bank of India, Mumbai

In the result, the appeal of the revenue is dismissed

ITA 1099/MUM/2023[2008-09]Status: DisposedITAT Mumbai27 Jun 2023AY 2008-09

Bench: Shri B.R. Baskaran & Shri Rahul Chaudhary

For Appellant: Shri Ketan VedFor Respondent: Shri Paresh Deshpande
Section 140ASection 244A

…interest on the balance amount due from the department to the assessee, on a particular date, does not amount to payment of interest on interest. Their lordships, taking support from the judgment of Hon'ble Supreme Court in the case of CIT v. HEG Ltd. [2010] 324 ITR 331/189 Taxman 335, observed as under: '14. Matter was taken by the Revenue before the Supreme Court in the case of HEG Limited and the SLP was granted and civil appeal was registered. The Supreme Court thereupon answered the question against the Revenue in the following words:- Therefore, this is not a case where the assessee is claiming compound in…

ACIT-2(2)(1), Mumbai vs. State Bank of India, Mumbai

In the result, the appeal of the revenue is dismissed

ITA 1098/MUM/2023[2007-08]Status: DisposedITAT Mumbai27 Jun 2023AY 2007-08

Bench: Shri B.R. Baskaran & Shri Rahul Chaudhary

For Appellant: Shri Ketan VedFor Respondent: Shri Paresh Deshpande
Section 140ASection 244A

…interest on the balance amount due from the department to the assessee, on a particular date, does not amount to payment of interest on interest. Their lordships, taking support from the judgment of Hon'ble Supreme Court in the case of CIT v. HEG Ltd. [2010] 324 ITR 331/189 Taxman 335, observed as under: '14. Matter was taken by the Revenue before the Supreme Court in the case of HEG Limited and the SLP was granted and civil appeal was registered. The Supreme Court thereupon answered the question against the Revenue in the following words:- Therefore, this is not a case where the assessee is claiming compound in…

ACIT-2(2)(1), Mumbai vs. State Bank of India, Mumbai

In the result, the appeal of the revenue is dismissed

ITA 1097/MUM/2023[2006-07]Status: DisposedITAT Mumbai27 Jun 2023AY 2006-07

Bench: Shri B.R. Baskaran & Shri Rahul Chaudhary

For Appellant: Shri Ketan VedFor Respondent: Shri Paresh Deshpande
Section 140ASection 244A

…interest on the balance amount due from the department to the assessee, on a particular date, does not amount to payment of interest on interest. Their lordships, taking support from the judgment of Hon'ble Supreme Court in the case of CIT v. HEG Ltd. [2010] 324 ITR 331/189 Taxman 335, observed as under: '14. Matter was taken by the Revenue before the Supreme Court in the case of HEG Limited and the SLP was granted and civil appeal was registered. The Supreme Court thereupon answered the question against the Revenue in the following words:- Therefore, this is not a case where the assessee is claiming compound in…

Hongkong & Shanghai Banking Corporatin Lt, Mumbai vs. ADIT (It)-3(1), Mumbai

In the result, the appeal of the assessee is dismissed

ITA 2866/MUM/2009[2002-03]Status: DisposedITAT Mumbai20 Jul 2022AY 2002-03
For Appellant: Shri Madhav KanhereFor Respondent: Smt. Neelam Shukla (DR)
Section 143(1)Section 143(3)Section 2Section 234DSection 244A

…same refers to the amount of refund without breaking it into or defining it in terms of its' elements. The interest chargeable there-under is compensatory in character, as in fact is the interest granted u/s. 244A. The Apex Court in CIT v. H.E.G. Ltd. [2010] 324 ITR 331/189 Taxman 335 (SC) directed for grant of interest u/s. 244A for the period of delay in grant of interest u/s. 244A itself; having been not granted along with the grant of refund of tax, so that it had assumed the character of the principal. Further, the tribunal in Dy. CIT v. Tube Investment of India Ltd. [IT Appeal Nos. 2221 & 2222 (Mad.) of 20…

DCIT Corporate Circle 1(1), Chennai vs. Ascendas Services (India) Pvt. Ltd., Chennai

In the result, the appeal filed by the Revenue is dismissed

ITA 2964/CHNY/2018[2007-08]Status: DisposedITAT Chennai15 Jun 2022AY 2007-08

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri Varuvooru Sreedhar, Addl.CITFor Respondent: Shri GSD Babu, Advocate
Section 154Section 244A

…ar No.11/2016 dated 24.04.2016, Instruction No.7/2013 dated 15.07.2013 and Instruction No.2/2007 dated 28.03.2007 and also the decisions of Hon’ble Supreme Court in the cases of Sandvik Asia Ltd vs. CIT, (2006) 150 taxman 591 (SC) and CIT vs. HEG Ltd., (2010) 324 ITR 331 (SC) and noted that the assessee is entitled for 4 interest on refund u/s.244A of the Act up to the date of actual grant of refund i.e., 11.11.2014. Now, the ld. Senior DR could not controvert the order of CIT(A) despite specific query asked by the Bench. The ld.Senior DR however relied on the order of AO rejecting the rectification application b…

Brakes India Limited, Chennai vs. DCIT (Ltu), Chennai

In the result, appeal filed by the assessee is dismissed

ITA 758/CHNY/2012[2002-03]Status: DisposedITAT Chennai23 Feb 2022AY 2002-03

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकरअपीलसं./I.T.A.No.758/Chny/2012 ("नधा"रणवष" / Assessment Year: 2002-03) M/S. Brakes India Ltd. Vs Deputy Commissioner Of Income Tax, (Ltu) Padi, Chennai-600 101. Chennai-600 050. Pan: Aaacb 2533Q (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 140ASection 143(3)Section 244A

…t in holding that the appellant is not entitled to the differential claim of interest u/s 244A on refund as claimed by it? 2) Whether the Tribunal was right in law in not following the judgment of the Hon’ble Supreme Court in the case of CIT Vs. H.E.G. Ltd. (324 ITR 331) holding that interest component will partake of the character of the amount due u/s 244A of the Act which becomes an integral part of the principal amount and assessee would be entitled to interest after the said amount becomes due and payable.” 5. The Hon'ble High Court of Madras vide its order in TCA No.53 of 2013 dated 05.02.2021 remitted th…

Kotak Mahindra Bank Ltd. (As Successor in Business of Erstwhile Ing Vysya Bank Ltd.), Mumbai vs. A.C.I.T. Cir. - 2(3)(2), Mumbai

In the result, all the appeals of the assessee are allowed

ITA 728/MUM/2018[1994-95]Status: DisposedITAT Mumbai27 Oct 2021AY 1994-95
Section 154Section 244ASection 245CSection 245D(1)

…of the Act thereon would tantamount to giving interest on interest which is against the provisions of the Act. We find that this aspect has been specifically addressed by the Hon’ble Supreme Court by 3 Judges Bench in the case of CIT vs H.E.G. Ltd reported in 324 ITR 331 (SC) wherein it was held as under:- 7. The next question which we are required to answer is - What is the meaning of the words "refund of any amount becomes due to the assessee" in section 244A? In the present case, as stated above, there are two components of the tax paid by the assessee for which the assessee was granted Refund, namely TDS of…

DCIT 2(2)(1), Mumbai vs. State Bank of India, Mumbai

The appeal stand dismissed

ITA 6271/MUM/2016[1995-96]Status: DisposedITAT Mumbai08 Oct 2021AY 1995-96

Bench: Hon’Ble Shri Vikas Awasthy, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am (Hearing Through Video Conferencing Mode) आयकरअपील सं./ I.T.A. No.6271/Mum/2016 (धििाारण वर्ा / Assessment Year: 1995-96) Dcit Circle-2(2)(1) State Bank Of India R. No. 545, Aaykar Bhavan Financial Reporting & Tax. Deptt. बिाम/ 3Rd Floor, Corporate Centre M. K. Road, Mumbai-400 021 Vs. State Bank Bhavan, Madam Cama Rd. Nariman Point, Mumbai-400 021. स्थायीलेखासं./ जीआइआरसं./ Pan/Gir No. Aaacs-8577-K (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : Revenue By : Shri Vijay Jaiswal– Ld. Cit-Dr Assessee By : Shri C. Naresh– Ld. Ar सुनवाई की तारीख/ : 25/08/2021 Date Of Hearing घोषणा की तारीख / : 08/10/2021 Date Of Pronouncement

For Appellant: Shri C. Naresh– Ld. ARFor Respondent: Shri Vijay Jaiswal– Ld. CIT-DR
Section 1Section 143(3)Section 154Section 2Section 244A

…. CIT(A) had granted relief to the assessee by placing reliance on the order of his predecessor in assessee’s own case for A.Y.1995-96 wherein reliance had been placed on the decision of the Hon’ble Supreme Court in the case of CIT vs. HEG Limited reported in 324 ITR 331 and decision of the Hon’ble Delhi High Court in the case of India Trade Promotion Organisation vs. CIT reported in 361 ITR 646. We find that the ld. DR fairly agreed that this issue is covered in favour of the assessee by the decision of this Tribunal rendered in the case of State Bank of Indore in ITA No.2972/Mum/2011. We also find that this Tri…

ACIT Circle-2(1)(1), Mumbai vs. M/S Bank of India, Mumbai

ITA 5683/MUM/2019[2001-02]Status: DisposedITAT Mumbai26 Jul 2021AY 2001-02

Bench: Shri Rajesh Kumar () & Shri Ravish Sood () Acit, Circle - 2(1)(1), M/S Bank Of India Room No. 561, 5Th Floor, Vs. 8Th Floor, Star House, Aayakar Bhavan, M.K. Road, C-5, G-Block, Bandra Kurla Mumbai – 400 020 Complex, Bandra (E), Mumbai – 400 051

For Appellant: Shri C. Naresh, A.RFor Respondent: Shri Tharian Oommen, D.R
Section 115JSection 143(3)Section 154Section 244ASection 250

…Organization (supra). In fact, the A.O was of the view that the Hon‟ble High Court of Delhi in the aforementioned case, viz. India Trade Promotion Orgnization (supra) had relied on the decision of the Hon‟ble Supreme Court in the case of H.E.G. Limited (2010) 324 ITR 331 (SC). Referring to the observations of the Hon‟ble Apex Court, the A.O therein observed, that when there is a refund of Rs. 1 lac due and only Rs.60,000/- was paid, then, first it shall be adjusted towards principal amount which is Rs.1 lac, and the department would be liable to pay interest on the balance amount of Rs.40,000/- only for the rest…

Awp Assistance (India) Pvt. Ltd., Gurgaon vs. DCIT, Circle- 1(1), Gurgaon

In the result, the appeal of the assessee is allowed

ITA 6585/DEL/2017[2013-14]Status: DisposedITAT Delhi08 Apr 2021AY 2013-14

Bench: Shri G.S. Pannu & Shri Kul Bharatassessment Year : 2013-14 Awp Assistance (India) Pvt. Ltd., Dcit, 1St Floor, Dlf Square, M-Block, Vs Circle-1(1), Jacaranda Marg, Dlf City, Gurgaon. Phase-Ii, Gurgaon-122002. Pan-Aafcm1460J Appellant Respondent Appellant By Sh. Salil Kapoor, Adv. & Ms. Saumya Singh, Adv. Respondent By Sh. Ashok Gautam, Sr. Dr Date Of Hearing 31.03.2021 Date Of Pronouncement 08.04.2021

Section 143(3)Section 154Section 244A

…the Revenue against the decision in Cholamandalam Investment and Finance Co. Ltd. [2007] 7 ITA No.-6585/Del/2017 294 ITR 438 (Mad , vide order dated December 3, 2009. The Supreme Court has also, recently, in the case of CIT v. H.E.G. Ltd. reported in [2010] 324 ITR 331 (SCI, vide its order dated December 3, 2009, held that the expression 'refund of any amount' would include interest under section 244A (on refund of tax deducted at source) to which the assessee was lawfully entitled but had been wrongly withheld by the Department." 10. It was further held that the amount of tax due on the returned income is to…

DCIT 2(2)(1), Mumbai vs. State Bank of India, Mumbai

In the result, the appeal of the revenue is partly allowed for statistical purposes

ITA 6273/MUM/2016[1996-97]Status: DisposedITAT Mumbai21 Oct 2020AY 1996-97

Bench: Shri Justice P P Bhatt & Shri M. Balaganesh, Am Dy.Commissioner Of Income Vs. State Bank Of India Tax Financial Reporting & Circle-2(2)(1) Taxation Department 3Rd Floor, Corporate Centre Mumbai State Bank Bhavan Madam Cama Road Nariman Point Mumbai – 400 021 Pan/Gir No. Aaacs8577K (Appellant) .. (Respondent)

Section 143(3)Section 36(1)(vii)Section 36(1)(viia)Section 41(4)

…IN THE INCOME TAX APPELLATE TRIBUNAL (VIRTUAL COURT), ‘G‘ BENCH MUMBAI BEFORE SHRI JUSTICE P P BHATT, PRESIDENT & SHRI M. BALAGANESH, AM Dy.Commissioner of Income Vs. State Bank of India Tax Financial Reporting & Circle-2(2)(1) Taxation Department 3rd Floor, Corporate Centre Mumbai State Bank Bhavan Madam Cama Road Nariman Point Mumbai – 400 021 PAN/GIR No. AAACS8577K (Appellant) .. (Respondent) Revenue by Shri Anand Mohan, CIT DR Assessee by Shri C. Naresh, C.A Date of Hearing 29/09/2020 Date of Pronouncement 21/10/2020 आदेश / O R D E R PER M. BALAGANESH (A.M): This appeal in ITA No.6273/Mum/2016 for A.Y…

Commissioner of Income Tax vs. M/S. Syndicate Bank

In the result, we do not find any merit in this appeal, the

ITA/582/2013HC Karnataka07 Oct 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 154Section 243(1)Section 244(1)Section 246ASection 260Section 260A

…law framed in the case of NARENDRA DOSHI supra has been answered in favour of the assessee. Our attention has also been invited to another three judge bench decision of the Supreme 9 Court in ‘COMMISSIONER OF INCOME TAX VS. H.E.G LTD’, (2010) 324 ITR 331 (SC) and has submitted that the interest component partakes the character of amount due under Section 244A of the Act. Reference has also been made to the decision of the Delhi High Court in ‘INDIA TRADE PROMOTION ORGANISATION VS. COMMISSIONER OF INCOME- TAX’, (2013) 38 TAXMANN.COM 233 (DELHI). Our attention has also been invited to par…

Oil and Natural Gas Corporation Ltd., Dehradun vs. DCIT, Dehradun

ITA 1434/DEL/2017[1991-92]Status: DisposedITAT Delhi28 Sept 2020AY 1991-92

Bench: Sh. Amit Shukladr. B. R. R. Kumar(E-Court Module) Ita No. 1434/Del/2017 : Asstt. Year : 1991-92 Oil & Natural Gas Corporation Ltd., Vs Dcit, Deputy General Manager (F&A)-Ctd, Circle-1, Corporate Tax Division, Room No. Dehradun-248001 244, Old Secretariat Building, Tel Bhawan, Dehradun-248003 (Appellant) (Respondent) Pan No. Aaaco1598A Assessee By : Sh. Ajay Vohra, Sr. Adv. Revenue By : Ms. Pramita M. Biswas, Cit Dr Date Of Hearing: 23.06.2020 Date Of Pronouncement: 28.09.2020

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Pramita M. Biswas, CIT DR
Section 140ASection 154Section 244ASection 244A(1)(b)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’, NEW DELHI Before Sh. Amit Shukla, Judicial Member Dr. B. R. R. Kumar, Accountant Member (E-Court Module) ITA No. 1434/Del/2017 : Asstt. Year : 1991-92 Oil and Natural Gas Corporation Ltd., Vs DCIT, Deputy General Manager (F&A)-CTD, Circle-1, Corporate Tax Division, Room No. Dehradun-248001 244, Old Secretariat Building, Tel Bhawan, Dehradun-248003 (APPELLANT) (RESPONDENT) PAN No. AAACO1598A Assessee by : Sh. Ajay Vohra, Sr. Adv. Revenue by : Ms. Pramita M. Biswas, CIT DR Date of Hearing: 23.06.2020 Date of Pronouncement: 28.09.2020 ORDER Per Dr. B. R. R. K…

Pr. Commissioner of Income Tax, Shimla vs. Ms Solan District Truck Operators Transport Co Operative Society Ltd Darlaghat Through President

ITA/5/2020HC Himachal Pradesh10 Sept 2020

Bench: HON'BLE MR. JUSTICE TARLOK SINGH CHAUHAN,HON'BLE MS. JUSTICE JYOTSNA REWAL DUA

For Appellant: Mr. Vinay Kuthiala, Sr. Advocate
Section 143Section 154Section 244Section 244A

…IN THE HIGH COURT OF HIMACHAL PRADESH, SHIMLA. ITA No. 5 of 2020 Decided on: 10.09.2020 Pr. Commissioner of Income Tax ...Appellant. Versus M/s Solan District Truck Operators Transport Co-op. Society …Respondent. __________________________________________________________ Coram: Hon’ble Mr. Justice Tarlok Singh Chauhan, Judge. Hon’ble Ms. Justice Jyotsna Rewal Dua, Judge. Whether approved for reporting? 1 No For the Appellant : Mr. Vinay Kuthiala, Sr. Advocate with Ms. Vandana Kuthiala, Advocate. (Through Video Conferencing) Tarlok Singh Chauhan, Judge (…

DCIT, New Delhi vs. M/S. Maruti Suzuki India Ltd., New Delhi

In the result, the appeals of the assessee are allowed and the appeals of the revenue are dismissed

ITA 599/DEL/2014[1994-95]Status: DisposedITAT Delhi31 Aug 2020AY 1994-95

Bench: Sh. Amit Shukladr. B. R. R. Kumar(E-Court Module) Ita No. 2553/Del/2013 : Asstt. Year : 1999-00 Maruti Suzuki India Ltd., Vs Commissioner Of Income Tax Plot No. 1, Nelson Mandela Road, (Appeals)-Ix, Income Tax Vasant Kunj, New Delhi-110070 Office, Laxmi Nagar, New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 2641/Del/2013 : Asstt. Year : 1999-00 Dcit, Vs Maruti Suzuki India Ltd., Circle-6(1), Plot No. 1, Nelson Mandela Road, New Delhi Vasant Kunj, New Delhi-110070 (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 468/Del/2014 : Asstt. Year : 1994-95 Maruti Suzuki India Ltd., Vs Jcit(Osd), Plot No. 1, Nelson Mandela Road, Circle-6(1), Vasant Kunj, New Delhi-110070 New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Pramita M. Biswas, CIT DR
Section 143(1)Section 244ASection 244A(1)Section 244A(1)(a)Section 244A(3)Section 254

…dia Ltd. amendment Act 1987. He also argued that based on the Circular of the CBDT No. 549 dated 31.10.1989, the assessee is eligible for the interest on the refund due. He further relied on the judgments of the Hon’ble Supreme Court in the case of CIT Vs HEG 324 ITR 331 and CIT Vs Chola Mandalam Investment and Finance Company 294 ITR 438. Relying on the various case laws, he argued that there is statutory liability on the revenue to pay the interest on general principles to pay the interest on sums wrongfully retained. 14. On the other hand, the ld. DR vehemently argued that the provisions of Section 244A(1)(a)…