IN THE HIGH COURT OF DELHI AT NEW DELHI 
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   ITA 345/2012  
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 CIT            ..... Appellant 
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 Through : Mr. Sanjeev Rajpal, Advocate. 
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 versus 
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 AGILENT TECHNOLOGIES INDIA PVT LTD..... Respondent 
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 Through :  Mr. Mayank Nagi, Advocate. 
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 CORAM: 
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 HON'BLE MR. JUSTICE SANJIV KHANNA 
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 HON'BLE MR. JUSTICE R.V.EASWAR 
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 O R D E R 
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     18.05.2012 
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 1. The issue is squarely covered by the decision of this Court in the 
 case of CIT v. Satlej Industries Limited (2010) 325 ITR 331 Delhi.    In 
 the said case it has been held that the self assessment tax paid by the 
 assessee is covered by Clause (b) to Section 244A(1), under the 
 expression ?any other case? used in the said Clause. 
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 2. It is noticeable that the Income Tax Appellate Tribunal (ITAT) has awarded interest with effect from 29th December 2006, i.e. the date on 
 which order under Section 143(3) of the Income Tax Act, 1961 was passed 
 and not from the date when the self assessment/tax was paid.  The order 
 of the tribunal, therefore, takes care of the objection raised by  the 
 Revenue that the assessee had filed revised return on 6th June, 
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 2006 and it is only after filing of the revised return that the assessee 
 became entitled to refund. 
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 3. We do not accept the contention of the revenue that the date 29th 
 December, 2006 should not be the starting point as the Assessing Officer 
 had made additions in the assessment order.  The additions were deleted 
 by the Commissioner of Income Tax (Appeals) [CIT(A)].  In these 
 circumstances, the date 29th December, 2006 is justified and the 
 appropriate date. 
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 4. The next contention raised by the Revenue is that the interest on 
 interest should not have been paid.  This issue is covered by the 
 decision of the Supreme Court in the case of CIT v. H.E.G. Ltd. (2010) 
 324 ITR 331 (SC).  In this case it has been held that the interest 
 component will partake of the character of the amount due under Section 
 244A and it becomes an integral part of the amount of refund due to the 
 assessee. 
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 5. The appeal has no merits and is accordingly dismissed.  No costs. 
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 SANJIV KHANNA, J. 
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 R.V.EASWAR, J. 
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 MAY 18, 2012 
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 AK 
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