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DELHI HIGH COURT
MANMOHAN, MANMEET PRITAM SINGH ARORA
Principal Commissioner of Income Tax – Appellant
Versus
Punjab & Sind Bank – Respondent


Table of Content
1. overview of the case and initial facts (Para 1 , 2)
2. arguments regarding interest on refund (Para 3 , 5 , 6 , 7 , 8)
3. court’s reasoning on interest definitions (Para 4 , 9 , 10 , 12 , 13 , 14 , 15 , 16 , 19 , 20 , 21)
4. legal basis for entitlement to interest (Para 17 , 22)
5. final ruling on the appeal (Para 18 , 24)

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 s

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