The dispute related to the manner in which the Revenue adjusted part refunds against outstanding tax demands. The Tribunal held that although the Act does not prescribe the method of adjustment, the principle underlying sections 140A and 220 requires adjustment first against the interest component and thereafter against the principal. Any other method would enable the Revenue to withhold the interest component indefinitely without compensating the assessee under section 244A. Such an adjustment does not amount to payment of interest on interest. Accordingly, the Revenue was directed to first adjust the refund against the outstanding interest component and thereafter against the principal while computing interest under section 244A. (AY. 1993-94 & 1998-99)