The Tribunal  remitted the matter  to NFAC for de novo adjudication considering the documents on record and the judgment of the jurisdictional High Court in Group M. Media India (P) Ltd. v. Dy. CIT (International Taxation) (2024) 336 CTR 270 (Bom)(HC) and pass a speaking order as per law complying with the principles of natural justice. NFAC is directed to take cognizance of the proposition that interest under s. 244A has to be granted upto the date when the actual refund was received while deciding the matter. (AY.2018-19)