The assessee had received the payment as a contractor on which the payer had deducted the tax at source . On refund the assessee claimed the interet on refunds .  The revenue  denied the interest on the ground that payments on which tax was deducted at source was returned by the assessee in the AY. 2005 -06 hence the interes cannot be paid on the refund for any period prior to the said assessment year .  The Tribunal directed the revenue to pay the interet for the AYs 2003 -04 , 2004 -05  and 2005 -06. On appeal by the revenue the Court held that,  interest  would be pyable from the respective assessment years. Starting point for computing the interest  payble must be to the assessment year in which the tax was deducted at source.  Followed  UOI v Tata Chemicals Ltd ( 2014) 363 ITR 658 (SC) ( AY. 2005 -06)