The Tribunal held that Expl. 2 to S. 234D is squarely applicable to the facts of the case as no additional interest had been computed under S.234D in the reassessment proceedings and therefore interest under section 234D is chargeable. ( AY. 1999-2000, 2002-03; 2003-04)
Dy. CIT v. Central Bank of India (2018) 191 TTJ 265/ 161 DTR 1 (Mum.)(Trib.)
S. 234D: Interest on excess refund – No additional interest had been computed under S. 234D in the reassessment proceedings and therefore interest is chargeable.