Coda Global LLC v. Dy. CIT (IT) (2024) 297 Taxman 299/339 CTR 314 /466 ITR 687 (Mad.)(HC)

S. 244A : Refund-Interest on refunds-Central Processing Centre (CPC)-Unable to input it foreign bank account details by imputing SWIFT code and IBAN as per ITR-Bank account is validated by revenue on 7-7-2023 and refund was made in October 2023 without interest-High Court directed the Revenue to pay interest on refund amount at rate specified in section 244A from 1-5-2022 to 5-10-2023. [S. 143(1), Art. 226]

 Assessee, a Limited Liability Company (LLC) incorporated in USA, sold equity shares in India to a buyer in USA who deducted income tax at 20 per cent of sale consideration.Assessee filed its return of income declaring a total income and claimed refund. Upon examining return, an intimation was issued under section 143(1) informing assessee that it was entitled to a certain refund However, as refund was not made, assessee raised grievances with Central Processing Centre (CPC) that it was unable to input it foreign bank account details by imputing SWIFT code and IBAN as per ITR. After being informed orally that refund claim could not be processed unless a bank account was set up in India, assessee set up a bank account in India and said bank account was validated by revenue on 7-7-2023 and refund was made in October 2023 without interest. On writ the Court held that when assessee requested department to enable assessee to provide SWIFT Code and IBAN, delay in processing of return could not be attributed to assessee and thus, revenue was to be directed to pay interest on refund amount at rate specified in section 244A from 1-5-2022 to 5-10-2023. (AY. 2021-22)