Question And Answer
Subject: Computation of interest u/s 244A(1A) as per MUMBAI ITAT TATA SONS PVT LTD is payable not on Refund of Tax payment including Interest due relying on SUPREME COURT CASE IN HEG LTD VS CIT
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Querist: Pankaj D Shah
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Date: July 26, 2026
Query asked by Pankaj D Shah
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Answer given by

According to the Mumbai ITAT in Tata Sons Pvt. Ltd. v. DCIT (2024) 204 ITD 802 (Mum.)(Trib.), interest under section 244A(1A) is computed with a specific adjustment method, relying on the Supreme Court’s interpretation in CIT v. HEG Ltd. (2010) 324 ITR 331 (SC).

The assessee becomes entitled to interest on the unpaid refund (including the interest component that should have been paid earlier).



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