On writ the Court held that one may call it interest on interest, but in reality payment of interest on the unpaid amount occurs because of non-payment of the total amount refundable, which is due and payable to the assessee consisting of the tax, which had to be refunded and the interest accrued on the delayed refund of the tax. The principal amount and the interest due are to be added and treated as the primary amount and interest becomes due and payable on this primary amount. It would be incorrect to treat it as compounding of interest .Accordingly the Court directed the Department to refund the entire amount, which was due and payable, including interest payable under section 244A of the Act .  (Writ and appeal )