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We allow this appeal and direct the Department to pay interest as prescribed under s. 244A of the IT Act as applicable at the relevant time at the earliest.

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Sec. 244A of Income-tax Act, 1961— Refund - The object behind insertion of s. 244A, as that, an assessee is entitled to payment of interest for money remaining with the Government which would be refunded and there is no reason to restrict the same to an assessee only without extending the similar benefit to a resident/deductor who has deducted tax at source and deposited the same before remitting the amount payable to a non-resident/foreign company, thus, there is no reason to deny payment of interest to the deductor who had deducted tax at source and deposited the same with the treasury - UNIVERSAL CABLES LTD. V/s CIT - [2020] 312 CTR 001 (SC)

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