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The division bench of Justice Manmohan and Justice Manmeet Pritam Singh Arora has observed that a sum has been found refundable to the assessee as a consequence of a reduction in the taxable income. The sum directed to be refunded to the assessee is a debt in the hands of the department, and for the department to term “payment of thiѕ debt” as “interest” is fallacious. In fact, it is on the payment of this debt that the assessee is demanding that the department be liable to pay interest for the period that the department retained the money. The Delhi High Court has held that an order under Section 241A of the Income Tax Act cannot be passed in a mechanical and routine manner. The refunds cannot be withheld just because the notice under Section 143 has been issued and the department wants to verify the claim for deduction under Section 10AA of the Income Tax Act. The Delhi High Court has held that the show cause notice as well as the reassessment order under Section 148A of the Income Tax Act were based on distinct and separate grounds.

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