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2025 (1) TMI 641

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..... ure (JCIT) -Ld. Sr. DR ORDER MANOJ KUMAR AGGARWAL (ACCOUNTANT MEMBER) 1. Aforesaid appeal by assessee for Assessment Year (AY) 2020-21 arises out of an order of learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [CIT(A)] dated 24-07- 2024 in the matter of an intimation issued by CPC u/s 154 of the Act. The sole grievance of the assessee is computation of .....

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..... 2020 to January, 2024. However Ld. CIT(A) denied the same on the ground that refund is granted the moment the concerned officer has signed the order regarding the payment of interest u/s 244A of the act. Reliance was placed on the decision of Hon'ble Rajasthan High Court in the case of Rajasthan State Electricity Board vs. CIT (281 ITR 274) to arrive at such a conclusion. Accordingly, the additio .....

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..... lved on 23-05-2023 by stating that intimation would be sent to the email ID once the processing gets completed. Since the same was still not forthcoming, the assessee raised another grievance on 07-08-2023 which was resolved on 10-08-2023 and it was stated that intimation u/s 154 would be sent once the processing gets completed. However, no intimation is shown to have ever been issued to the asses .....

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..... e of Nokia Solutions and Networks India (P) Ltd. vs. Addl. CIT (169 Taxmann.com 537) has held that interest on refund is to be calculated till the date the funds are released to the assessee and not till the date of order accepting the assessee's claim for grant of refund. The expression 'refund is granted' would necessarily mean refund of payment of the amount. The interest is paid to compensate .....

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