Held that since there was no adjudication by Chief Commissioner/Commissioner on period for which interest was to be excluded on refund payable to assessee, AO could not invoke section 154 to rectify assessment and disallow interest under section 244A on ground that interest payable on refund was attributable to delay caused by assessee. (AY. 2007-08)
Grasim Industries Ltd. v. DCIT (2022) 197 ITD 542 / 99 ITR 69 (SN)/ 220 TTJ 273/ 219 DTR 169 (Mum.) (Trib.)
S. 154 : Rectification of mistake-Mistake apparent from the record-Refunds-Interest-No adjudication by Chief Commissioner / Commissioner-Additional ground-Denial of interest by passing rectification order is held to be not valid. [S. 244A (2)]