Allowing the petition the Court held that  with regard to the refund to be returned with the interest, sub-section (1A) inserted in section 244A had to be applied prospectively for the period of delay after introduction of the relevant statutory provision. Under sub-section (1) of section 244A the Department had to grant interest at the statutory rate and both the provisions, sections 244 and 244A, applied and the Department had to grant the refund accordingly. Directed to comply the direction within three months. Failure to comply the direction compensation shall be paid of Rs. 1lakh  (AY.2005-06)