Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita No.750/Kol/2025 (निर्धारण वर्ा / Assessment Year : 1992-93) Jcit (In Situ), Circle-1(1), Vs The Peerless General Finance Kolkata & Investment Company Limited Peerless Bhawan, 3, Esplanade East, Kolkata-700069 Pan No. :Aabct 3043 L (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) रधजस्व की ओर से /Revenue By : Shri Sushanta Saha, Addl. Cit निर्धाररती की ओर से /Assessee By : Shri S.K.Tulsiyan, Advocate & Ms. Puja Somani, Ca सुनवाई की तारीख / Date Of Hearing : 31/07/2025 घोषणा की तारीख/Date Of Pronouncement : 26/08/2025 आदेश / O R D E R Per Rajesh Kumar, Am : This Is An Appeal Filed By The Revenue Against The Order Dated 26.09.2017, Passed By The Ld. Cit(A)-22, Kolkata, For The Assessment Year 1992-93. 2. At The Outset, We Observe That There Is A Delay Of 39 Days In Filing The Appeal By The Revenue For Which The Condonation Petition Has Been Filed. After Perusing The Contents Of Condonation Petition, We Are Inclined To Condone The Delay & Admit The Appeal For Adjudication. 3. The Only Issue Raised By The Revenue In The Various Grounds Of Appeal Is Against The Order Of The Ld. Cit(A) Holding That The Assessee Is Entitled To Interest On Unpaid Interest Whereas There Is No Provisions As Per The Income Tax Act To Charge The Interest On Unpaid Interest On The Assessee As Well As Nowhere The Powers Give Rights To The Assessing Officer To Give Interest On Unpaid Interest To The Assessee.
TDS of Rs. 45,73,528 and tax paid after original assessment of Rs. 1,71,00,320. The Department contends that the words "any amount" will not include the interest which accrued to the respondent for not refunding Rs. 45.73,528 for 57 months. We see no merit in this argument. The interest component will partake of the character