PCIT v. Amrutlal Madhavjibhai Bharad (2025) 476 ITR 1 / 305 Taxman 413 (SC) Editorial : Mohanbhai Madhavjibhai Bharad v. PCIT (2024) 465 ITR 313/ 336 CTR 578 /158 taxmann. com 13 (Guj) (HC)

S. 244A : Refunds-Interest on refunds-Deduction of tax at source-Delay in application under circumstances beyond control of assessee-Delay is condoned-Entitled to interest on refund-Money held without authority-High Court directed the revenue to grant interest-SLP delayed by 371, 390 and 374 days-SLP of revenue was dismissed on account of delay and also on merit. [S. 194LA, IT R, 1962, R. 31(3), form 16A, Art. 136]

The High Court, on writ petitions  seeking refund of the tax deducted at source on the interest on the compensation for acquisition of the assessees’ agricultural lands, directed the grant of refund to the assessees under section 244A of the Income-tax Act, 1961, holding that the assessees were not at fault for the delay in claiming refund as no tax was payable by the assessees on interest under section 194LA of the Act. SLP of revenue was dismissed as the  delay of 371, 390 and 374 days, respectively, had not been satisfactorily explained. Even otherwise, there was no good reason to interfere with the orders passed by the High Court. (AY. 2013-14)

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