JUDGMENT :

(Easwaran S., J.)

This intra-court appeal is preferred by the Revenue aggrieved by the judgment dated 7.1.2025 of the learned Single Judge in WP(C) No.21868/2024 directing the appellants to grant interest on the amount of refund ordered.

2. The brief facts for the disposal of the appeal are as follows:

The 1^st respondent-assessee approached the writ court aggrieved by the inaction on the part of the appellants in not releasing interest on the amount of refund to which the 1^st respondent-assessee was entitled to in pursuance to issuance of a certificate in Form-5 under Sections 5(2) r/w 6 of the Direct Tax Vivad se Vishwas Act, 2020. By an order of assessment under Section 143(3) of the Income Tax Act, 1961 for the assessment year 2016-17, the assessee was assessed to a total income of Rs.1,86,80,000/-, which includes an addition of Rs.75,00,000/- as unexplained investment. In the meantime, the assessee filed a declaration and undertaking under sub-Section (5) of Section 4 of the Direct Tax Vivad se Vishwas Act, 2020 ('Act', for short). On filing of the said undertaking and declaration, a certificate was drawn by the Assistant Commissioner of Income Tax, Central Circle-I, Koz