- (1.) This order will dispose of four writ petitions bearing CWP Nos. 69, 1080 and 1724 of 1990 and 8499 of 1993. For the sake of convenience, facts are being taken from CWP No. 69 of 1990.
(2.) The petitioner challenged an order dt. 27th June, 1989, copy Annex. P-10, passed by the CIT, Patiala, whereby revision petitions filed by the petitioner under Section 264 of the IT Act, 1961 (for short 'the Act'), for the asst. yrs. 1978-79, 1979-80, 1980-81 were dismissed by a common order.
(3.) The claim of the petitioner was that the interest entitlement of the petitioner under Section 244(1A)/214(1A) of the Act has not been worked out properly by the IAC (Asst.), Patiala. The petition filed by the assessee against the order of 1AC, Patiala, was dismissed by the CIT, by passing a sketchy and non-speaking order. Though, the assessee at the time of hearing, while referring to a series of judgments, which according to him support its case, argued that the claim of the petitioner needs to be accepted in toto and the petitioner is entitled to interest on delayed refund of interest as well. The judgments being National Agricultural Co-operative Marketing Federation of India Ltd. v. Union of India and Ors., CIT v. Leader Engineering Works, Modi Industries Ltd. v. CIT, CIT v. Saswad Mali Sugar Factory Ltd., Sandvik Asia Ltd. v. CIT and CIT v. Orissa Cement Ltd. (2001) 119 Taxman 742 (Del).;