The assessee applied under the VSV Act, 2020 and in full and final settlement Form 5 under the provisions of the VSV Act, 2020 was issued entitling the assessee to refund. The refund was not issued. On writ the Court held that once Form 5 under the VSV Act, 2020 was issued entitling the assessee to a refund of Rs. 2,19,42,954, there was no question of the respondents then requiring to file Form 26B as now sought to be demanded by the respondents. Obligation to refund money received and retained without right implies and carries with it the right to interest. The Revenue is directed to make payment of refund of Rs. 2,19,42,954 along with interest @ 6 per cent per annum on the delayed refund amount w.e.f. 20th Dec., 2022 i.e. beyond the period of 90 days from the date of determination of refund amount on 20th Sept., 2022 till the date of actual payment to the assessee. (AY.2008-09)