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Section 244A Interest Cannot Be Denied for Post-Refund Determination Delay: Bombay HC

Case Law Details

TaxGuru Citation
2026 taxguru.in 8927
Case Name
Bedmutha Industries Limited Vs ACIT (Bombay High Court)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2017-18
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Bedmutha Industries Limited Vs ACIT (Bombay High Court)

Material Facts

The petitioner challenged an order dated 25 April 2024 rejecting its claim for interest on an income-tax refund under Section 244A of the Income-tax Act, 1961 up to the date of actual payment. The petitioner sought a direction to compute and pay interest until the refund was actually released.

For Assessment Year 2017-18, the petitioner filed its original return on 29 October 2017 claiming a refund of Rs.1,60,47,550 and filed a revised return on 31 January 2019 claiming the same refund. The return was processed under Section 143(1) on 14 November 2019, determining the refund together with interest under Section 244A amounting to Rs.25,67,600 up to the date of intimation. Subsequently, an assessment order under Section 143(3) dated 24 December 2019 accepted the returned loss and again determined the refund along with the same amount of interest.

According to the petitioner, although the refund had been determined, it was not released despite repeated letters, grievances, and validation of bank accounts. The refund was ultimately credited only in March 2023. The petitioner thereafter sought interest under Section 244A until the date of actual payment, but the request was rejected on the ground that the delay was attributable to incorrect bank details furnished by the petitioner.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 19,653

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