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TMI Blog1986 (2) TMI 113X X X X Extracts X X X X X X X X Extracts X X X X ..... the Act on refund of Rs. 2,50,000. The assessment year involved is 1980-81 and the order under appeal is dt.22nd June, 1984passed by the CIT (A)-IX,New Delhi. 2. The necessary facts for purpose of deciding this appeal are that the assessee company entered into a technical collaboration agreement with M/s. Sybron Corporation,New York,USAon31st May, 1979for manufacture of electronic range of inst ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... granted necessary refund alongwith ITNS 150A. The assessee did not appeal against the said order. Later, on 7th Nov., 1983, an application under s. 154 was moved for getting the ordered of 4th March, 1983 rectified and it was stated that interest under s. 244 (1A) on refund of Rs. 2,50,000 should have been granted. 4. The ITO rejected the above stated application under s. 154 on the ground that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... March, 1983 should have been made alongwith interest; and (b) that the first appellate authority erred in not considering the order under s. 195 and the order thereon under s. 250 as orders covered by s. 244(1A) of the Act. Shri Ganeshan took pains to explain to us that the word "assessment" under s. 244(1A) of the Act should be seen any analysed in the context of related provisions, particularly ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ecause the assessee's request for interest came by way of s. 154 rectification application. By simply observing that the proposition canvassed before us regarding the interpretation of s. 244 (1A) rest necessarily on debate and two opinions are admittedly possible, we reject the appeal on the short ground that s. 154 rectification has a limited scope and does not stipulate resolving of controversy ..... X X X X Extracts X X X X X X X X Extracts X X X X
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