- (1.) Heard counsel for the parties.
(2.) In this case, the admitted case of both the parties is that under the scheme the certificate was issued of Rs. 9,902/- and that amount was paid. The Respondents accepted the amount without any demeanor. Subsequently, they became wiser that the Petitioner was also required to pay interest on this amount as is required under Section 220 of the Income Tax Act. May be that understanding of the Respondents was in the light of law for some semblance of the authority, but in view of the decision of the Hon'ble Supreme Court in the case of Sushila Rani (Smt.) v. Commissioner of Income Tax, 2002 2 SCC 697, once a certificate is issued and the payment is made it is not open to the Respondent to have reopened the question for payment of interest.
(3.) In the view of the matter, this writ petition is allowed and the demand as raised by the Respondents is quashed.;