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2005 (12) TMI 69 - HC - Income TaxInterest – refund - On noticing that interest under section 214 has been calculated on the refund due as per the original assessment order, by totally ignoring the amended section 214, the petitioner filed a revision application before the Commissioner of Income-tax under section 264 of the Income-tax Act. The said revision came to be rejected – held that revision could not be rejected only on ground of delay – further, held therein that the Taxation Laws (Amendment) Act, 1984 is procedural in nature and, therefore, it will apply to all the pending actions. This being so, sub-section (1A) which was introduced in section 214 will apply to the petitioner's case. There is no substance in the second ground of rejection of revision. - impugned order passed by the Commissioner of Income-tax is set aside. The respondents are accordingly directed to pay the interest to the petitioner as permissible u/s 214(1A)
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