This compilation indexes twelve writ petitions decided by the Karnataka High Court, Madras High Court, and Bombay High Court — spanning September 2019 to November 2025 — in which taxpayers invoked Section 244A of the Income Tax Act, 1961 in disputes concerning interest on income-tax refunds. The compilation is intended for in-house tax teams, Big-4 associates, and law-firm researchers who need a structured reference point for locating relevant High Court proceedings on refund-interest entitlement, computation, and enforcement. Each entry reproduces only the identity fields and source-preview information available in the underlying structured corpus; it does not constitute a full-text digest of any judgment.

Research index only. This page is a structured case-law reference compiled from court records. Nothing on this page constitutes legal advice, tax advice, or a recommendation of any course of action. Always verify against the full authenticated judgment text and check for subsequent stays, appeals, or reversals before relying on any entry.

The statutory framework in one paragraph

Section 244A of the Income Tax Act, 1961 provides for the payment of interest by the Central Government to a taxpayer on refunds arising out of excess payment of advance tax, tax deducted or collected at source, or self-assessment tax paid under Section 140A. The section specifies the rate of interest, the period for which interest is payable, and the circumstances in which interest may be reduced or excluded — including periods attributable to the assessee's own delay. Sub-section (1A), inserted subsequently, provides for an additional interest obligation in cases where refunds are not issued within the time prescribed. The provision operates as a statutory entitlement designed to compensate the taxpayer for the time value of money withheld by the Revenue beyond the period permitted by law.

The 12 rulings

1. Honeywell Technology Solutions Lab vs Deputy Commissioner Of Income Tax

Bench: Karnataka High Court
Date: 7 November 2025
Sections engaged: 143(3), 244A
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP No. 29023 of 2024) was filed under Article 226 of the Constitution of India before the Karnataka High Court at Bengaluru, praying to direct the respondents to forthwith refund an amount of Rs. 3,78,59,031/- together with applicable interest for Assessment Year 2006-07 as marked in Annexure-X1. The petition came on for orders and an oral order was made; the substantive outcome is not specified in the source preview.

2. M/S Kaypee Electronics And Associates vs The Deputy Commissioner Of Income Tax

Bench: Karnataka High Court
Date: 24 April 2025
Sections engaged: 244A, 143(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP No. 1307 of 2025) was filed under Articles 226 and 227 of the Constitution of India before the Karnataka High Court at Bengaluru, seeking a writ in the nature of mandamus directing the first respondent to grant refund of taxes paid under protest as per tax challans along with interest under Section 244A of the Act for AY 2010-11. The petition came on for orders; the substantive outcome is not specified in the source preview.

3. Rangabashyam Mahalakshmi vs The Income Tax Officer

Bench: Madras High Court
Date: 24 March 2025
Sections engaged: 244A
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (W.P. No. 10639 of 2024) was filed under Article 226 of the Constitution of India before the Madras High Court, seeking a writ of mandamus to direct the first respondent to consider the petitioner's representation dated 12.01.2024 and consequently issue interest on refund due under Section 244A of the Income Tax Act, 1961 till the date of granting of the refund. The substantive outcome of the petition is not specified in the source preview.

4. United Capital Partners India Pvt. Ltd vs Principle Commissioner Of Income Tax

Bench: Madras High Court
Date: 2 January 2025
Sections engaged: 5(1), 244A
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (W.P. No. 25404 of 2021, reserved on 08.11.2024 and pronounced on 02.01.2025) was filed under Article 226 of the Constitution of India praying for a writ of certiorarified mandamus to quash Form 3 issued under Section 5(1) of the Direct Tax Vivad Se Vishwas Act, 2020 dated 14.06.2021, and to direct the respondent to issue a revised Form 3 and grant time to complete the settlement under the Vivad Se Vishwas Act, 2020; the petition also engaged Section 244A in the context of the balance refundable amount. The substantive outcome is not specified in the source preview.

5. Vodafone Idea Limited vs The Centralized Processing Cell (TDS)

Bench: Karnataka High Court
Date: 22 April 2024
Sections engaged: 244A
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP No. 9121 of 2024) was filed under Article 226 of the Constitution of India before the Karnataka High Court at Bengaluru by Vodafone Idea Limited (formerly known as Vodafone South Limited, subsequently merged with Vodafone Mobile Services Limited and then with Idea Cellular Limited), with respondents including the Centralized Processing Cell (TDS), the Deputy Commissioner of Income-Tax (International Taxation), and the Commissioner of Income-Tax. The appeal was directed at a refund and interest entitlement under Section 244A; the substantive outcome is not specified in the source preview.

6. Ibm India Private Limited vs The Deputy Commissioner Of Income Tax

Bench: Karnataka High Court
Date: 19 March 2024
Sections engaged: 244A
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP No. 7016 of 2024) was filed under Article 226 of the Constitution of India before the Karnataka High Court at Bengaluru, praying to direct the respondents to forthwith refund an amount commencing "Rs. 154,0..." (full figure not available in the source preview) along with applicable interest under Section 244A. Respondents included the Deputy Commissioner of Income Tax (International Taxation Circle), the Commissioner of Income Tax, the Centralized Processing Center, and the Director General of Income Tax (Systems); the substantive outcome is not specified in the source preview.

7. Coda Global Llc vs (1) The Deputy Commissioner Of Income

Bench: Madras High Court
Date: 9 January 2024
Sections engaged: 143(1), 244A
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (W.P. No. 26634 of 2023) was filed under Article 226 of the Constitution of India before the Madras High Court, praying for a writ of mandamus directing the first respondent to grant refund of the amount determined and compensatory interest; the prayer in the source preview references a determination under the Income Tax Act, 1961 and Section 244A. The substantive outcome is not specified in the source preview.

8. M/S Myntra Designs Private Limited vs The National Faceless Assessment

Bench: Karnataka High Court
Date: 16 November 2023
Sections engaged: 241A, 143(1), 244A
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP No. 19995 of 2023) was filed under Article 226 of the Constitution of India before the Karnataka High Court at Bengaluru by M/S Myntra Designs Private Limited, with respondents including the National Faceless Assessment Centre, the Deputy Commissioner of Income Tax, the Additional Commissioner of Income Tax, the Principal Commissioner of Income Tax, and the Central Processing Cell. The petition engaged Sections 241A, 143(1), and 244A; the substantive outcome is not specified in the source preview.

9. Mantelone Investment Ltd vs The Commissioner Of Income-Tax (It)

Bench: Bombay High Court
Date: 15 September 2021
Sections engaged: 244A, 143(3), 154
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP No. 1246 of 2021) was filed before the Bombay High Court (Ordinary Original Civil Jurisdiction) by Mantelone Investment Ltd., a Cyprus-registered entity, against the Commissioner of Income-Tax (IT) Mumbai-3, the Deputy Commissioner of Income Tax (International Tax), and the Union of India. The source preview indicates that the petitioner's income included interest income earned by subscribing to interest-bearing securities, and the petition engaged the computation of disputed tax, interest, and penalty in the context of Section 244A and related provisions; the substantive outcome is not specified in the source preview.

10. M/S. Saipem India Projects Private vs The Deputy Commissioner Of Income-Tax

Bench: Madras High Court
Date: 3 September 2021
Sections engaged: 244A
Outcome: Outcome not specified in source
Procedural / substantive ground: The batch of writ petitions (W.P. Nos. 17754, 17756, 17758, 17761, 17762, 17764 of 2021) was filed under Article 226 of the Constitution of India before the Madras High Court, seeking a writ of mandamus directing the first respondent to refund the tax of Rs. 8,02,746 determined in the giving effect order passed in F. No. AAAC17915F/2017-18 for AY 2010-11 dated 20.02.2018, along with interest under Section 244A of the Act till the date of actual issuance/disbursement of such refund. The third respondent (Deputy Director, Centralized Processing Cell, Ghaziabad) was suo motu impleaded by the Court; the substantive outcome is not specified in the source preview.

11. Wipro Limited vs The Joint Commissioner Of Income Tax

Bench: Karnataka High Court
Date: 25 August 2021
Sections engaged: 244A, 153(5)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP No. 20040/2019) was filed under Articles 226 and 227 of the Constitution of India before the Karnataka High Court at Bengaluru, praying to quash the direction in the order passed by Respondent No. 2 dated 29.03.2019, and for grant of additional interest under Section 244A(1A) from the expiry of the time prescribed under Section 153(5) of the Act. The source preview indicates that the Court's order addressed the issue of additional interest in the context of fresh assessment/re-assessment and the applicable time limits under Section 153(5); the substantive outcome is not specified in the source preview.

12. Areva T & D India Limited vs /

Bench: Madras High Court
Date: 30 September 2019
Sections engaged: 244A, 140A, 143
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP No. 22862 of 2008) was filed under Article 226 of the Constitution of India before the Madras High Court, praying for a writ of certiorarified mandamus to quash the order of the Commissioner of Income Tax/R1 dated 31.03.2008 rejecting the request for grant of interest under Section 244A on an amount of Rs. 2 crores paid by the petitioner on 28.06.1996 as self-assessment tax. The petitioner challenged the rejection of its claim for refund interest on self-assessment tax paid under the provisions engaged, including Section 140A and Section 143; the substantive outcome is not specified in the source preview.

Patterns across these 12 rulings

Writ jurisdiction as the primary enforcement route. Across all twelve entries, taxpayers approached High Courts under Article 226 (and in some cases also Article 227) of the Constitution of India seeking writs of mandamus or certiorarified mandamus to compel the Revenue to grant refunds together with interest under Section 244A. This indicates that ordinary appellate channels were, in these instances, considered insufficient or unavailable to enforce a refund-interest entitlement.
International taxation circles are disproportionately represented. Several cases — including Coda Global LLC, Saipem India Projects, Vodafone Idea, Mantelone Investment, and IBM India — involve the International Taxation circles of the Assessing Officer or have a cross-border dimension to the underlying income. This pattern suggests that refund-interest disputes in international taxation assessments are a recurring litigation category under Section 244A.
Centralized Processing Cell (CPC) frequently joined as a respondent. In multiple petitions — including Myntra Designs, IBM India, Saipem India Projects, and Vodafone Idea — the Centralized Processing Center (CPC/TDS) was named as a respondent alongside the field assessing officer. This reflects the operational reality that refund issuance and interest computation are often handled through automated CPC systems, creating a division of responsibility that taxpayers must address in litigation.
Long-standing disputes and delayed refunds. The date range of the underlying assessment years (as far back as AY 2006-07 in Honeywell and a payment date of 28.06.1996 in Areva T&D) relative to the date of the writ petition illustrates that Section 244A disputes frequently arise from prolonged delays between the original tax payment and the actual credit of refund, making the interest entitlement a significant amount in controversy.
Section 244A(1A) and additional interest in re-assessment contexts. The Wipro Limited petition specifically engaged Section 244A(1A) — the additional interest provision — in conjunction with Section 153(5), raising the distinct question of whether the additional interest clock runs from the expiry of the time prescribed for completion of fresh assessment or re-assessment. This sub-provision issue appears as a discrete litigation strand within the broader Section 244A category.

How to use this compilation

This compilation is a starting index, not a substitute for the full judgment text. Each entry records the writ petition number, court, date, sections engaged, and the prayer as available in the structured source preview. Researchers should use these identifiers to retrieve the complete authenticated judgment from indiankanoon.org, the official High Court portal (e.g., mhc.tn.gov.in/judis for Madras, Karnataka High Court's official portal, or Bombay High Court's portal), or a licensed legal database. The outcome field for all twelve entries is recorded as "Outcome not specified in source" because the dispositive holding could not be confirmed from the available text preview; do not treat absence of an outcome as indicative of any particular result.

Before placing reliance on any ruling listed here, verify whether the judgment has been stayed, appealed to a Division Bench, taken to the Supreme Court, or otherwise varied or reversed. Refund-interest disputes often generate multi-round litigation, and a Single Judge order may have been modified on appeal. Additionally, check for any CBDT instructions, circulars, or administrative guidelines issued after the date of the judgment that may affect the practical implementation of any direction made by the Court.

Researchers working on Section 244A matters should also examine whether any relevant CBDT circular or instruction on refund-interest computation — including instructions to the CPC regarding automated interest calculation — is applicable to the taxpayer's specific fact pattern. Court rulings on the section operate alongside, and sometimes in response to, administrative guidance; a complete research picture requires consulting both streams of authority.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 244A Refund Interest: 12 High Court Rulings (2019–2025)