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TMI Blog2012 (6) TMI 631X X X X Extracts X X X X X X X X Extracts X X X X ..... hat there was no provision in the Act for allowance of interest on interest – Held that:- in the case of Sandvik Asia Ltd.( 2006 (1) TMI 55 (SC)) has clearly held that when amounts are wrongfully retained by the Government, then, on general principle, interest has to be paid. AO directed to allow interest on interest in accordance with the decision of Hon’ble Supreme Court in the case of Sandvik Asia Ltd. (supra). - ITA. No.5054/Mum/2010, ITA. No.4754/Mum/2010 - - - Dated:- 31-1-2012 - D K Agarwal, T R Sood, JJ. For Appellant: C G K Nair For Respondent: Aarti Sathe ORDER Per: T R Sood: These are two cross appeals are directed against the order of CIT(A)-10, Mumbai, relating to assessment year 2001-02. ITA No.5054/M ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ded that u/s.244A(1)(b) even interest on self-assessment tax was required to be paid by the Revenue and in this regard reliance was placed on the decision of Madras High Court in the case of CIT vs. SIV Industries Ltd. (295 ITR 114) and CIT vs. Cholamandalam Finance Investment Co. Ltd. (294 ITR 438) . Similar view has been taken even by the Karnataka High Court in the case of CIT v. NGEF Ltd. (161 CTR 280) . The ld. CIT(A) agreed with this submission and also found that even the Mumbai Bench of Tribunal in the case of ACIT v. Grindwell Norton Ltd. (100 ITD 245) has taken a similar view and accordingly he held that interest u/s.244A is allowable even against the payment of self-assessment tax. 5. Before us, the ld. DR s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... both the parties, we find that before the CIT(A) an additional ground was taken for claim of interest on interest u/s.244A. Before him, reliance was placed on the decision of Hon ble Supreme Court in the case of Sandvik Asia Ltd. vs. CIT (280 ITR 643) . Reliance was placed on following decisions of the Tribunal : (i) Mumbai ITAT in case of Novartis India Ltd. (WTA No.74/M/04) for Wealth-tax A.Y. 1993-94. (ii) Mumbai ITAT in case of Novartis India Ltd. (ITA No.1992/M/04) for A.Y. 1996-97. (iii) Mumbai ITAT in case of Novartis India Ltd. (ITA No.1711/M/03) for A.Y. 1996-97). (iv) Mumbai ITAT in case of Sandoz Private Ltd. (ITA Nos.1994 1995/M/05 for A.Ys. 1998-99 1999-00. (v) Mumbai ITAT in case of Grasim Industries Lt ..... X X X X Extracts X X X X X X X X Extracts X X X X
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