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“interest on refund”

InterestSection 244ASection 244A278 judgments

The decision most relied on for interest on refund is Sandvik Asia Ltd. v. CIT (280 ITR 643), cited in 96 judgments on BharatTax.

Leading authorities on interest on refund

Sandvik Asia Ltd. v. CIT
280 ITR 643 · 2006 · Supreme Court
96
citing judgments

Assessees are entitled to compensation for the inordinate delay by the Income Tax Department in refunding excess tax, which includes interest on the statutory interest due under section 244A for such delayed refunds.

Union of India v. Tata Chemicals Ltd.
363 ITR 658 · 2014 · Supreme Court
91
citing judgments

The Department has a moral and legal obligation to refund excess tax collected from taxpayers, along with interest. An assessee is entitled to interest on the amount of taxes refunded, including interest on interest, as per Section 244A of the Income-tax Act.

CIT v. Pfizer Ltd.
330 ITR 62 · 2011 · High Court
78
citing judgments

An insurance claim received on stock in trade constitutes business income and is not an independent source of income.

CIT v. Oriental Insurance Co. Ltd.
125 Taxmann 1094 · 2002 · High Court
77
citing judgments

Interest levied under Section 201(1A) for delayed remittance of Tax Deducted at Source (TDS) is compensatory in nature, not penal. It is a distinct provision for delayed remittance, similar to interest paid by Revenue on refunds.

CIT v. Gujarat Fluoro Chemicals
358 ITR 291 · 2013 · Supreme Court
72
citing judgments

An assessee is not entitled to interest on interest under section 244A of the Income-tax Act, particularly regarding interest granted on a refund.

Union Bank of India v. ACIT
72 Taxmann.com 348 · 2016 · ITAT
69
citing judgments

A tax refund must first be adjusted towards interest payable under Section 244A, with the balance then appropriated against the principal tax amount. This approach does not lead to interest on interest.

CIT v. HEG Ltd.
324 ITR 331 · 2010 · Supreme Court
63
citing judgments

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".

India Trade Promotion Organisation v. CIT
361 ITR 646 · 2014 · High Court
54
citing judgments

When a refund is due to an assessee under Section 244A, the amount must first be adjusted towards the interest payable on such refund, with the balance then adjusted against the tax amount refundable. This follows the principle of Section 140A(1) and means "any amount" in Section 244A includes accrued interest.

Judgments citing interest on refund

American Chemical Society, Usa vs. DCIT (International Tax), Circle 1(1)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 1603/MUM/2025[2022-23]Status: DisposedITAT Mumbai13 Nov 2025AY 2022-23

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2022-23

For Respondent: Mr. Vishal Karla
Section 143(3)Section 144C(13)Section 9(1)(vi)

erred in computing the correct amount of interest on Ld. AO has erred in computing the correct amount of interest on refund under Section 244A of the Act. refund under Section 244A of the Act. 6. That on the facts and circumstances of the case

DCIT Circle 4(2), New Delhi vs. Canon India Pvt. Ltd., New Delhi

In the result, to sum up and conclude:

ITA 1038/DEL/2023[2005-06]Status: DisposedITAT Delhi10 Nov 2025AY 2005-06

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Shri Vijay B. Basanta, CIT-DR
Section 10ASection 143(3)Section 254Section 92C

India Pvt Ltd "9. We find that both the Commissioner of Income Tax (Appeals) and the Tribunal have while examining the claim for interest on refund granted, considered the fact that the relief under Section 90 of the Act is available in respect of the income tax which is payable ... find that both the Commissioner of Income Tax (Appeals) and the Tribunal have while examining the claim for interest on refund granted, considered the fact that the relief under Section 90 of the Act is available in respect of the income tax which is payable both in India as well

Canon India Pvt. Ltd, Gurugram vs. Neac, Delhi

In the result, to sum up and conclude:

ITA 585/DEL/2021[2003-04]Status: DisposedITAT Delhi10 Nov 2025AY 2003-04

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Shri Vijay B. Basanta, CIT-DR
Section 10ASection 143(3)Section 254Section 92C

India Pvt Ltd "9. We find that both the Commissioner of Income Tax (Appeals) and the Tribunal have while examining the claim for interest on refund granted, considered the fact that the relief under Section 90 of the Act is available in respect of the income tax which is payable ... find that both the Commissioner of Income Tax (Appeals) and the Tribunal have while examining the claim for interest on refund granted, considered the fact that the relief under Section 90 of the Act is available in respect of the income tax which is payable both in India as well

Yashita Finance Pvt. Ltd., New Delhi vs. CIT(A), New Delhi

Appeal is allowed

ITA 6200/DEL/2025[2016-17]Status: DisposedITAT Delhi30 Oct 2025AY 2016-17

Bench: Sh. Satbeer Singh Godaraita No. 6200/Del/2025 : Asstt. Year : 2016-17 Yashita Finance Pvt. Ltd., Vs Income Tax Officer, 8-A, Commissioner Lane, Civil Lines, Ward-27(4), New Delhi-110054 New Delhi (Appellant) (Respondent) Pan No. Aaacy3088P Assessee By: Ms. Tinya, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 30.10.2025 Date Of Pronouncement: 30.10.2025 Order

For Appellant: Ms. Tinya, AdvFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 14ASection 2Section 271(1)(c)

amounting to Rs.5,76,947/- which pertains to various disallowance u/s 14A, legal and professional expenditure, interest on refunds u/s 2 Yashita Finance Pvt. Ltd. 244A and difference in interest income etc. involving varying sums, respectively. 4. The above being the clinching factual position, the Revenue could hardly dispute that

Checkmate Facility & Electronic Solution Pvt. Ltd., Ahmedabad vs. The Dy. CIT, Circle-1(1)(1), Vadodara

In the result, appeal filed by the assessee is partly allowed for statistical purposes

ITA 234/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad29 Oct 2025AY 2017-18

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), Ms. SUCHITRA KAMBLE (Judicial Member)

For Appellant: Ms. Kinjal Shah, ARFor Respondent: Shri Rameshwar P Meena, Sr.DR
Section 244ASection 250

order was passed within seven days. It is submitted that Sec. 244A does not apply since the alleged interest on Refund in Income-tax is adjusted against the demand without permission/sanction/knowledge of the Appellant which is against Law and Equity and therefore the Addition of Rs.5,04,705/-be deleted

Suzlon Gujarat Wind Park Limited, Ahmedabad vs. The Dy.CIT, Circle-4(1)(1), Ahmedabad

ITA 382/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad08 Oct 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Tushar Hemani, Sr. AdvFor Respondent: Shri B. P. Srivastav, Sr. DR
Section 139(1)Section 139(5)Section 154Section 244ASection 244A(1)(a)Section 251(2)

facts of the case in confirming the rejection of rectification application u/s. 154 of the Act for short grant of interest on refund u/s. 244A of the Act. 2. The Ld. CIT(A) has erred in law and on facts of the case in holding that the appellant ... facts of the case in not following the order for preceding year passed by his predecessor allowing short grant of interest on refund u/s. 244A of the Act on identical facts. 7. The Ld. CIT(A) has erred in law and on facts of the case in holding that

Lummus Technology Heat Transfer B.V, Gurugram vs. The Assistant Commissioner of Income Tax, Int. Tax, Gurugram

In the result, appeal of the assessee is allowed

ITA 3741/DEL/2023[2021-22]Status: DisposedITAT Delhi06 Oct 2025AY 2021-22

Bench: Shri Vikas Awasthy & Shri Naveen Chandraआअसं.3741/िद"ी/2023(िन.व. 2021-22) Lummus Technology Heat Transfer B.V, Second Floor, Infinity Tower B, Dlf Cyber City, Sector 25A, Phase Ii, Gurugram, Haryana 122001 ...... अपीलाथ"/Appellant Pan: Aabca-9045-K बनाम Vs. Assistant Commissioner Of Income Tax, International Taxation, Gurugram, ..... "ितवादी/Respondent Haryana 122001 अपीलाथ" "ारा/ Appellant By : Shri Vishal Kalra, Advocate, Ms. Reema Grewal, Chartered Accountant & Ms. Snigdha Gautam, Advocate "ितवादी"ारा/Respondent By : Shri Nikhil Kumar Govila, Cit सुनवाई क" ितिथ/ Date Of Hearing : 07/07/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 06/10/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Dated 27.10.2023, Passed U/S. 143(3) R.W.S 144C(13) Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’). 2. The Gist Of Grounds Raised By The Assessee In Appeal Assailing The Assessment Order Is As Under:

For Appellant: Shri Vishal Kalra, AdvocateFor Respondent: Shri Nikhil Kumar Govila, CIT
Section 143(3)Section 40Section 80G

circumstances of the case and in law, the AO has erred in not granting the credit of tax deduced at source on interest on refund amounting to INR 26,83,615.” 4. Shri Vishal Kalra, appearing on behalf of the assessee narrating facts of the case submits that the assessee

DCIT, Swargate Pune vs. Honeywell Automation India Limited, Pune

ITA 2180/PUN/2024[2010-11]Status: DisposedITAT Pune03 Oct 2025AY 2010-11

Bench: Hon’Ble Smt Astha Chandra & Shri G. D. Padmahshali

For Appellant: Mr Siddhesh Chougule[‘Ld. AR’]For Respondent: Mr Gaurav Singh [‘Ld. DR’]
Section 10A(7)Section 143(1)Section 143(3)Section 246ASection 250Section 271(1)(c)Section 274

denial of tax exemption claimed u/s 10A(7) & 10AA(9) of the Act for sum of 53,64,06,922/-, (3) addition of interest on refund received 34,93,040/- and (4) variation of income as per 26AS for sum of 18,56,131/-. In consequence vide notice dt. 30/01/2015 ... purposes. Pursuant to the direction of the Tribunal, the Ld. AO passed order giving effect [‘OGE’] dt. 16/03/2020 whereby addition on account of interest on refund and variation of income as per 26AS continued but addition on account of TP adjustment finally restricted

Colgate Palmolive (India) Limited, Mumbai vs. Principal Commissioner of Income Tax -6, Mumbai

In the result, appeal of the assessee is allowed

ITA 3293/MUM/2025[2018-19]Status: DisposedITAT Mumbai29 Sept 2025AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

For Appellant: Shri J D Mistry, Sr. AdvocateFor Respondent: Shri R A Dhyani, CIT DR
Section 143(3)Section 144Section 263Section 37(1)Section 80G

Income from Business or 9,68,34,57,848 Profession Income from other sources 244A Interest on Refund Interest Income 27,25,34,751 Less: Tax free interest income 2,22,21,350 25,03,13,401 Total Income from other 25,03,13,401 sources Income from House Property

Kotak Mahindra Bank Limited, Mumbai vs. DCIT 2(3)(1), Mumbai

In the result, all the grounds of appeal of assessee is allowed

ITA 4633/MUM/2025[2021-22]Status: DisposedITAT Mumbai03 Sept 2025AY 2021-22

Bench: Shri Pawan Singh& Smt.Renu Jauhri

Section 143(1)Section 143(3)Section 147Section 237Section 244ASection 244A(1)(a)Section 244A(1)(b)Section 246ASection 246A(1)(b)Section 246A(1)(i)

have been granted. Ground No. 4- Interest under section 244A(1)(b) of the Act 1. The CIT(A) erred in not granting interest on refund of Rs.4,40,96,577 from the date on which the order giving effect to the CIT(A) order was passed i.e. 10th February ... account. Ground No. 5-Short-granting of interest u/s 244A(1) for 1 month 1. The CIT(A) erred in short granting of interest on refund under section 244A, short by one (1) month resulting in a reduced refund to the Appellant. 2. The CIT(A) failed to appreciate that

Kotak Mahindra Bank Limited, Mumbai vs. DCIT 2(3)(1), Mumbai

In the result, all the grounds of appeal of assessee is allowed

ITA 4632/MUM/2025[2020-21]Status: DisposedITAT Mumbai03 Sept 2025AY 2020-21

Bench: Shri Pawan Singh& Smt.Renu Jauhri

Section 143(1)Section 143(3)Section 147Section 237Section 244ASection 244A(1)(a)Section 244A(1)(b)Section 246ASection 246A(1)(b)Section 246A(1)(i)

have been granted. Ground No. 4- Interest under section 244A(1)(b) of the Act 1. The CIT(A) erred in not granting interest on refund of Rs.4,40,96,577 from the date on which the order giving effect to the CIT(A) order was passed i.e. 10th February ... account. Ground No. 5-Short-granting of interest u/s 244A(1) for 1 month 1. The CIT(A) erred in short granting of interest on refund under section 244A, short by one (1) month resulting in a reduced refund to the Appellant. 2. The CIT(A) failed to appreciate that

Kotak Mahindra Bank Limited, Mumbai vs. DCIT 2(3)(1), Mumbai

In the result, all the grounds of appeal of assessee is allowed

ITA 4631/MUM/2025[2020-21]Status: DisposedITAT Mumbai03 Sept 2025AY 2020-21

Bench: Shri Pawan Singh& Smt.Renu Jauhri

Section 143(1)Section 143(3)Section 147Section 237Section 244ASection 244A(1)(a)Section 244A(1)(b)Section 246ASection 246A(1)(b)Section 246A(1)(i)

have been granted. Ground No. 4- Interest under section 244A(1)(b) of the Act 1. The CIT(A) erred in not granting interest on refund of Rs.4,40,96,577 from the date on which the order giving effect to the CIT(A) order was passed i.e. 10th February ... account. Ground No. 5-Short-granting of interest u/s 244A(1) for 1 month 1. The CIT(A) erred in short granting of interest on refund under section 244A, short by one (1) month resulting in a reduced refund to the Appellant. 2. The CIT(A) failed to appreciate that

Kotak Mahindra Bank Limited, Mumbai vs. DCIT 2(3)(1), Mumbai

In the result, all the grounds of appeal of assessee is allowed

ITA 4630/MUM/2025[2018-19]Status: DisposedITAT Mumbai03 Sept 2025AY 2018-19

Bench: Shri Pawan Singh& Smt.Renu Jauhri

Section 143(1)Section 143(3)Section 147Section 237Section 244ASection 244A(1)(a)Section 244A(1)(b)Section 246ASection 246A(1)(b)Section 246A(1)(i)

have been granted. Ground No. 4- Interest under section 244A(1)(b) of the Act 1. The CIT(A) erred in not granting interest on refund of Rs.4,40,96,577 from the date on which the order giving effect to the CIT(A) order was passed i.e. 10th February ... account. Ground No. 5-Short-granting of interest u/s 244A(1) for 1 month 1. The CIT(A) erred in short granting of interest on refund under section 244A, short by one (1) month resulting in a reduced refund to the Appellant. 2. The CIT(A) failed to appreciate that

Kotak Mahindra Bank Limited, Mumbai vs. DCIT 2(3)(1), Mumbai

In the result, all the grounds of appeal of assessee is allowed

ITA 4629/MUM/2025[2016-17]Status: DisposedITAT Mumbai03 Sept 2025AY 2016-17

Bench: Shri Pawan Singh& Smt.Renu Jauhri

Section 143(1)Section 143(3)Section 147Section 237Section 244ASection 244A(1)(a)Section 244A(1)(b)Section 246ASection 246A(1)(b)Section 246A(1)(i)

have been granted. Ground No. 4- Interest under section 244A(1)(b) of the Act 1. The CIT(A) erred in not granting interest on refund of Rs.4,40,96,577 from the date on which the order giving effect to the CIT(A) order was passed i.e. 10th February ... account. Ground No. 5-Short-granting of interest u/s 244A(1) for 1 month 1. The CIT(A) erred in short granting of interest on refund under section 244A, short by one (1) month resulting in a reduced refund to the Appellant. 2. The CIT(A) failed to appreciate that

Kotak Mahindra Bank Limited, Mumbai vs. DCIT 2 3 1, Mumbai

In the result, all the grounds of appeal of assessee is allowed

ITA 4628/MUM/2025[2015-16]Status: DisposedITAT Mumbai03 Sept 2025AY 2015-16

Bench: Shri Pawan Singh& Smt.Renu Jauhri

Section 143(1)Section 143(3)Section 147Section 237Section 244ASection 244A(1)(a)Section 244A(1)(b)Section 246ASection 246A(1)(b)Section 246A(1)(i)

have been granted. Ground No. 4- Interest under section 244A(1)(b) of the Act 1. The CIT(A) erred in not granting interest on refund of Rs.4,40,96,577 from the date on which the order giving effect to the CIT(A) order was passed i.e. 10th February ... account. Ground No. 5-Short-granting of interest u/s 244A(1) for 1 month 1. The CIT(A) erred in short granting of interest on refund under section 244A, short by one (1) month resulting in a reduced refund to the Appellant. 2. The CIT(A) failed to appreciate that

ACIT-27(1), Mumbai vs. Gammon Neelkanth Realty Corporation, Mumbai

ITA 1897/MUM/2024[2011-12]Status: DisposedITAT Mumbai02 Sept 2025AY 2011-12

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri Swapnil Choudhary, Sr. DRFor Respondent: Shri Nitesh Joshi, Adv. &
Section 250

development of property. The assessee filed the return of income for AY 2010-11 on 15.10.2010 declaring income of Rs. 22,829/- towards interest on refund and a business loss of Rs. 17,35,024/-. The case was selected for scrutiny and the statutory notices were duly served

ACIT 27(1), Mumbai vs. Gammon Neelkanth Realty Corporation, Mumbai

ITA 1896/MUM/2024[2010-11]Status: DisposedITAT Mumbai02 Sept 2025AY 2010-11

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri Swapnil Choudhary, Sr. DRFor Respondent: Shri Nitesh Joshi, Adv. &
Section 250

development of property. The assessee filed the return of income for AY 2010-11 on 15.10.2010 declaring income of Rs. 22,829/- towards interest on refund and a business loss of Rs. 17,35,024/-. The case was selected for scrutiny and the statutory notices were duly served

The Madras Seva Sadan, Chennai vs. ACIT, Exemption, Chennai

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1246/CHNY/2025[2022-23]Status: DisposedITAT Chennai08 Aug 2025AY 2022-23

Bench: Shri George George K & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1246/Chny/2025 Assessment Years: 2022-23 The Madras Seva Sadan, The Assistant Commissioner Of No.7, Shenstone Park, Income Tax (Exemption), Harrington Road, Chetpet, Chennai. Chennai-600 031. [Pan: Aaatt2871J] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Shri R.Venkatanarayanan, Advocate प्रत्यर्थी की ओर से /Revenue By : Ms.R.Anitha, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 07.08.2025 घोषणा की तारीख /Date Of Pronouncement : 08.08.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Shri R.Venkatanarayanan, AdvocateFor Respondent: Ms.R.Anitha, Addl.CIT
Section 139Section 140ASection 143Section 143(1)Section 155Section 199Section 206CSection 244A

further, we deem it appropriate to extract the statutory stipulations prescribed in section 244A. “……Section - 244A, Income-tax Act, 1961 - FA, 2025 90[Interest on refunds. 91 244A. 92 (1) 93[Where refund 94 of any amount becomes due to the assessee 94 under this Act], he shall, subject

The South Indian Bank Limited, Thrissur vs. DCIT, Thrissur

In the result, the appeal of the assessee stands partly allowed for statistical purposes

ITA 182/COCH/2025[2007-08]Status: DisposedITAT Cochin06 Aug 2025AY 2007-08

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Assessment Year: 2007-08 The South Indian Bank Ltd., .......... Appellant Head Office, Mission Quarters, T.B. Road, Thrissur. [Pan: Aabct 0022 F] Vs. Dy Commissioner Of Income Tax .......... Respondent Circle-1(1) & Tps, Thrissur.

For Appellant: Shri Naresh C, CAFor Respondent: Smt. Veni Raj, CIT-DR
Section 143(3)Section 244A

perused the material available on record. The issue that arises for our determination is with regard to computation of amount of eligible interest on refund due to the appellant bank. The amount of refund was determined 3 The South Indian Bank Ltd.. pursuant to the consequential order passed

M.S. Khurana Engineering Limited, Ahmedabad vs. The DCIT, Circle-2(1)(2), Ahmedabad

ITA 2171/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2014-15

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Shri Deepak Rindani, ARFor Respondent: Shri R.P. Rastogi, CIT-DR &
Section 14ASection 80Section 80I

have not attained finality, hence, we find merit in the aforesaid contention of the Ld.Counsel for the assessee. It is directed that the interest on refund, if any, will be charged to tax in the year in which the matter attains finality and interest, if any, is actually received