Judgment

Dr. A.R. Lakshmanan, J.—These appeals raise substantial and important questions of law of great general public importance as well as under the Income Tax Act, 1961 pertaining to assessment years 1977-78, 1978-79, 1981-82 and 1982-83 requiring consideration of this Court. Since common questions of law and facts arise in all these appeals they were heard together and are being disposed of by this common judgment. The impugned common judgment was passed by the High Court of Bombay rejecting the appellant’s claim on interest holding that no such interest on interest is payable under any of the provisions of the Income Tax Act, 1961 (for short ‘the Act’).

2. The main issue raised in these appeals is whether an assessee is entitled to be compensated by the Income-tax Department for the delay in paying to the assessee amounts admittedly due to it? The delay in the instant case was for various periods ranging from 12 to 17 years.

3. The following facts are not in dispute:-

Assessment Year 1977-78:

Notice of demand was issued to the appellant by respondent No.2 for advance tax payable of Rs.2,74,31,250/-.The appellant paid a sum of Rs.1,86,04,450/-. Assessment order was passed by respon