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In view of the ratio laid down by the Hon'ble Supreme Court in the judgment supra, the interest on the delayed refund becomes part of the principle amount and the delayed interest includes the interest for not refunding the principle amount. Accordingly, it also includes the interest on the delayed refund.

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Sec. 244A of the Income-tax Act, 1961 - Refund - The monetary limit to prefer an appeal before High Court is less than Rs. 1.00 crore, but if there is a valid question, where an Order, Notification, Instruction or Circular is to be challenged as illegal or ultra vires, an appeal could be filed before the High Court. Since no such exception was available to the appellant, Tax Appeal of the revenue dismissed. - PR. CIT V/s AMBUJA DARLA KASHLOG MANGOO TRANSPORT CO-OPERATIVE SOCIETY - [2020] 269 TAXMAN 618 (HP)

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