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Issues involved: The issues involved in this judgment are related to the grant of interest under section 244A of the Income Tax Act on self-assessment tax paid by the assessee and the entitlement to interest on interest under the same section.
Grant of Interest u/s 244A on Self-Assessment Tax: The Appellate Tribunal considered the case where the Assessing Officer did not grant interest on self-assessment tax paid by the assessee, leading to an appeal before the CIT(A). The CIT(A) directed the Assessing Officer to grant interest on the excess payment of self-assessment tax from the date it was paid by the assessee, relying on relevant legal precedents and CBDT Circulars. The Tribunal upheld the CIT(A)'s decision, emphasizing that the legislative intent of section 244A is to compensate the assessee for the use of funds by the Government. The Tribunal also distinguished a previous High Court judgment cited by the revenue, stating that it did not mandate interest on self-assessment tax only from the date of regular assessment. Therefore, the Tribunal dismissed grounds 2 to 7 raised by the revenue. Entitlement to Interest on Interest u/s 244A: Regarding the CIT(A)'s direction to grant interest on interest, the Tribunal referred to a Supreme Court decision in the case of Sandvik Asia v CIT, which stated that the assessee is entitled to interest on the amount to be refunded under section 244(1) from the date it ought to be granted. The Tribunal agreed with the CIT(A)'s direction to quantify the period for which interest has to be paid on the interest due to the assessee, based on the Supreme Court's decision. Consequently, ground no. 8 raised by the revenue was also dismissed. In conclusion, the appeal filed by the revenue was dismissed by the Appellate Tribunal, upholding the decisions of the CIT(A) regarding the grant of interest under section 244A on self-assessment tax and interest on interest.
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