JUDGMENT

Manmeet Pritam Singh Arora, J. (Oral)--The present appeal has been filed by Revenue-Appellant impugning the order dated 29th June, 2018, passed by the Income Tax Appellate Tribunal (hereinafter referred to `ITAT') in ITA No. 5486/Del/2014 for the Assessment Year ('AY') 2001-02.

2. Briefly stated the facts are that initially, the income of assessee i.e. the respondent herein was assessed at Rs.73,17,35,961/- vide an order dated 19th January, 2010. Consequent to the above, a demand for payment of interest under Section 234D(2) and Section 220(2) of the Income Tax Act, 1961 ('the Act') was raised by Revenue on the respondent herein. However, upon subsequent re-computation of the income vide an order dated 3rd February, 2010, passed under Sections 154/250/143(3) of the Act, the income of the assessee was assessed at Rs.40,88,00,550/- after setting-off brought forward losses for AY 1996-1997. Consequently, as a result of the reduction of taxable income, the respondent herein was entitled to refund of sum deposited as interest under Section 234D and Section 220 (2) of the Act. The assessee was held entitled to refund of a sum of Rs.1,66,46,933/- under Section 234D and a sum o