JUDGMENT

Santosh Hegde, J.-Being aggrieved by an order made by the Division Bench of the High Court of Karnataka in Writ Petition Nos.17068-70 of 1988, the appellant is before us in these appeals.

2. In respect of assessment years 1977-78, 1978-79 and 1980-81, assessment orders were served on the assessee-appellant and demand notices were issued. The appellant complied with the demands by paying the tax due. The appellate authority on an appeal preferred by the appellant, allowed the same and the taxes paid were refunded to the appellant. The appellate tribunal dismissed the appeal filed by the Revenue and on a Reference made to the High Court, the same came to be allowed thereby upholding all the assessment orders. Thereafter, the Revenue made fresh demands and the assessee re-paid the taxes as assessed and demanded. However, the Revenue invoked Section 220(2) of the Income Tax Act, 1961 (the Act) and demanded interest in respect of the tax assessed for the period commencing with refund of the tax consequent upon the first appellate order till the taxes were finally paid after disposal of References.

3. The appellant challenged the said demand of interest in the above-mentioned writ