K.M. Joseph, J.

1. Appellants are respondent Nos. 1 to 3 in the writ petition. Respondent No. 1 Bank filed a writ petition seeking the following reliefs:

“(a) Issue a writ, order or direction in the nature of mandamus directing the respondent No. 2 and 3 to refund to the petitioner the entire amount which it has coercively recovered on 29-03-2014 along with 15% interest per annum, as per sections 240 and 244(1) of ITA.

(b) Issue any other writ, order or direction in the nature of certiorari quashing letter dated 04-12-2014 (Annexure No. 5) issued by the Respondent No. 3 granting an illusory refund and instead direct respondent No. 2 and 4 to make actual refund under section 240 and 244(1) along with interest @ 15%.”

2. Very briefly put, the case of respondent No. 1/writ petitioner was as follows:

On 18.07.2014, the Income Tax Appellate Tribunal, Delhi Bench, in three appeals, passed a judgment and allowed the appeals filed by the writ petitioner and dismissed the appeals filed by the Income Tax Department (hereinafter referred to as the “Department”) holding that the provision of Section 194A(1) of the Income Tax Act (hereinafter referred to as the “Act”) is not applicable to