Allowing the petition the Court held that ; merely because one application was decided by the Commissioner and another by the Chief Commissioner there could not be a distinction. The assessee was not entitled to any interest on refund even if ultimately allowed by the Department till June 8, 2011. If the delay was condoned and the effect of condonation was that the return filed by the assessee after the delay was treated as a valid return filed on the date of its submission to the Department, the period as envisaged in the proviso to sub-section (2) of S. 143 would have lapsed. Therefore, the return should be treated to have been validly filed from the date of this order for the purpose of scrutiny and completion of assessment, if taken in scrutiny. All consequential provisions for scrutiny, final assessment and limitation would consequentially apply. (AY. 2009-10)