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TMI Blog2014 (10) TMI 262X X X X Extracts X X X X X X X X Extracts X X X X ..... it shall also apply to an assessment year commencing before 1/06/2003 - The only qualifying criterion is that proceedings in respect of such assessment is completed after 1/06/2003 - once the Explanation is held to be retrospective in relation to the assessment years commencing before 1/6/2003 it would not be open to restrict the operation of section 234D only with effect from 1/6/2003 - Under the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of payment of such amount up to the date on which refund is actually granted – Decided against revenue. - Income Tax Appeal No. 801 of 2012 - - - Dated:- 12-9-2014 - S. C. Dharmadhikari And A. K. Menon,JJ. For the Petitioner : Mr. Tejveer Singh For the Respondents : Mr. R. Murlidhar Mr. A. K. Jasani ORDER P.C. 1. When this matter was called out for admission, Mr.Tejveer ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... al was argued for sometime, Mr.Tejveer Singh and Mr.Murlidhar, conceded that insofar as the question (a) is concerned that is a substantial question of law and fully covered against the Assessee and in favour of the Revenue by the order of this Court dated 12.09.2012 in Income Tax Appeal No.2012/2011 and since reported in (2012) 78 ITR 361 : (2012) 254 CTR 113 (The Commissioner of Income Tax v/s M ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... evant statutory provision and for the Assessment Year in question was identically worded as that of Section 244A standing today. Our attention is then invited to the Tribunal's order and impugned in this Appeal. Mr.Murlidhar submits that in paragraph 7 of the impugned order the Tribunal has extensively referred to the judgment of the Delhi High Court in the case of Commissioner of Income Tax v ..... X X X X Extracts X X X X X X X X Extracts X X X X
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