JUDGMENT judgment of court was delivered by R. K. Gauba J.-This appeal under section 260A of Income-tax Act, 1961, assails order dated September 30, 2011 of Income-tax Appellate Tribunal (hereinafter referred to as "the ITAT") passed in Income Tax Appeal No. 5392/Del/2010 in respect of respondent (assessee) for assessment year 2006-07, holding assessee to be entitled to interest under section 244A on excess self-assessment tax paid under section 140A, thereby upholding order dated September 20, 2010, to such effect passed by Commissioner of Income-tax (Appeals) (hereinafter referred to as "the CIT (Appeals)" in Appeal No. 75/2010-2011 that had been preferred by assessee against order dated December 31, 2008, of Assessing Officer (AO) under section 143(3). Though appellant had also raised questions in respect of deletion of amount of Rs. 69 lakhs which had been added by Assessing Officer by invoking section 14A read with rule 8D of Income-tax Rules appeal to that extent was not entertained as calculation of disallowance under section 14A was found covered by ruling in Maxopp Investment Ltd. v. CIT [2011] 203 Taxman 364 (Delhi); [2012] 347 ITR 272 (Delhi). By order dated September 22, 2014, following substantial question of law was formulated: "Whether, on facts and in circumstances of case, Income-tax Appellate Tribunal was correct in law in confirming order of Commissioner of Income-tax (Appeals) that assessee shall be entitled to interest under section 244A of Income-tax Act, 1961, in respect of excess self-assessment tax paid?" background facts relevant for purposes of addressing abovenoted question of law only need to be captured here. assessee is Government of India undertaking established under Ministry of Petroleum and Natural Gases primarily engaged in providing engineering and technical consultancy services and execution of contracts on turn-key basis, predominantly in oil/gas/hydrocarbon sectors. It had filed return on November 13, 2006, for assessment year 2006-07 declaring income of Rs. 2,40,13,53,030 followed by revised return on November 23, 2008, declaring income of Rs. 2,43,29,60,025. Assessing Officer selected case of assessee for scrutiny and issued notice under section 143(2) read with section 142(1) of Incometax Act. During course of assessment proceedings, Assessing Officer noticed that assessee had claimed dividend income amounting to Rs. 2 crores as exempt under section 10(33) which, according to Assessing Officer, was not justified. Eventually, Assessing Officer held that amount of Rs. 69,00,000 required to be disallowed on pro rata basis under section 14A read with rule 8D of Income-tax Rules. appeal of assessee against abovesaid assessment order was partly allowed by Commissioner of Income-tax (Appeals) which restricted disallowance to Rs. 25,000. It was in course of hearing before Commissioner of Income-tax (Appeals) that assessee raised question of Assessing Officer not having allowed interest under section 244A of Income-tax Act on amount in excess deposited as self-assessment tax. contentions of appellant were noted by Commissioner of Income-tax (Appeals) as under: "As per intimation processed under section 143(1) of Act, appellant was eligible to claim refund of Rs. 78,123,227 and such refund was on account of excess self-assessment tax paid by appellant. As per provisions of section 244A of Act, where tax is paid by way of tax collected at source or by way of advance tax or treated as paid under section 199 of Act, no interest shall be payable if amount of refund is less than ten per cent. on regular assessment. As per provisions of section 244A(1)(b) of Act, interest shall be payable even if amount is less than 10 per cent. as proviso only applied to section 244A(1)(a)of Act. law is well settled for refund on account of excess payment of self-assessment tax that assessee is entitled to interest. Reliance is placed on Madras High Court in case of CIT v. Cholamandalam Investment and Finance Co. Ltd. [2007] 294 ITR 438 (Mad); ([2008] 166 Taxman 132 (Mad))." plea of assessee was upheld by Commissioner of Income-tax (Appeals) with observations to following effect: "On perusal of aforesaid proviso to section 244A(1)(a), it is evident that, in case amount of refund is less than ten per cent. of tax determined in regular assessment, interest is not payable if refund is on account of TDS, TCS or advance tax. However, in case refund is due to excess payment of self-assessment tax, such restriction is not applicable. This view is in line with decision of Madras High Court in case of CIT v. Cholamandalam Investment and Finance Co. Ltd. [2007] 294 ITR 438 (Mad); [2008] 166 Taxman 132 (Mad), and Delhi High Court. Accordingly, I hold to allow interest under section 244A of Income-tax Act to appellant on refund due on account of payment of excess self-assessment tax." Revenue took out appeal before Income-tax Appellate Tribunal, inter alia, in context of aforementioned direction concerning admissibility of interest on excess self-assessment tax paid. Noting submission that, according to intimation under section 143(1), assessee was eligible for refund of Rs. 7,81,23,227, assessee was held to be entitled to interest as granted by Commissioner of Income-tax (Appeals) on excess self-assessment tax paid under section 140A in terms of section 244A. legality of order of Income-tax Appellate Tribunal to above effect is challenged by Revenue primarily raising following contentions: "The Income-tax Appellate Tribunal erred in not examining fact as to whether assessee has raised issue of interest on selfassessment tax before Assessing Officer or not. order of Assessing Officer is silent on this issue. If assessee has not raised this issue earlier, he should not be allowed to raise same before Commissioner of Income-tax (Appeals) and/or Income-tax Appellate Tribunal. Income-tax Appellate Tribunal has failed to appreciate that assessee has paid total tax of Rs. 81,89,34,346 during year under consideration and claimed refund of Rs. 7,80,48,467. After giving credit of TDS advance tax and excess self-assessment tax, amount of refund was less than 10 per cent. of total tax. As per provisions of sections 244A(1)(a) no interest is payable if amount of refund is less than 10 per cent. of tax as determined under subsection (1) of section 115WE or sub-section 143(1) or on regular assessment. Income-tax Appellate Tribunal has filed to appreciate that from bare perusal of section 244A of Income-tax Act, it becomes clear that assessee is not entitled for interest on excess self-assessment tax. Unlike other sections, i.e., section 115WJ (fringe benefit tax), section 206C (tax collected at source), section 199 (advance tax), section 140A (self-assessment tax) does not find any mention in section 244A. assessee is thus not entitled for any interest on selfassessment tax." Revenue relies on decisions of Supreme Court in Sandvik Asia Ltd. v. CIT [2006] 280 ITR 643 (SC); [2006] 2 SCC 508, CIT v. Gujarat Fluoro Chemicals [2013] 358 ITR 291 (SC); [2013] 296 ELT 433 (SC) and Union of India v. Tata Chemicals Ltd. [2014] 363 ITR 658 (SC); [2014] 6 SCC 335 to contend that interest is payable to assessee only if it is so provided under statute. Per contra, respondent-assessee refers to CIT v. Sutlej Industries Ltd. [2010] 325 ITR 331 (Delhi) to argue that interest on self-assessment tax paid under section 140A to extent it has been found to be excess is admissible since such payment would fall within expression "refund of any amount". Reliance is also placed on decision of High Court of Bombay in case of Stock Holding Corporation of India Ltd. v. N. C. Tewari, CIT Manu/MH/2146/2014 since reported in [2015] 372 ITR 282 (Bom). Section 244A of Income-tax Act which is at core of this dispute, as it stands after amendment by Finance Act, 2005, with effect from April 1, 2006, to extent relevant, reads as under: "244A. Interest on refunds.-(1) Where refund of any amount becomes due to assessee under this Act, he shall, subject to provisions of this section, be entitled to receive, in addition to said amount, simple interest thereon calculated in following manner, namely:- (a) where refund is out of any tax paid under section 115WJ or collected at source under section 206C or paid by way of advance tax or treated as paid under section 199, during financial year immediately preceding assessment year, such interest shall be calculated at rate of one per cent. for every month or part of month comprised in period from 1st day of April of assessment year to date on which refund is granted: Provided that no interest shall be payable if amount of refund is less than ten per cent. of tax as determined under sub-section (1) of section 115WE or sub-section (1) of section 143 or on regular assessment; (b) in any other case, such interest shall be calculated at rate of one per cent. for every month or part of month comprised in period or periods from date or, as case may be, dates of payment of tax or penalty to date on which refund is granted. Explanation.-For purposes of this clause,'date of payment of tax or penalty' means date on and from which amount of tax or penalty specified in notice of demand issued under section 156 is paid in excess of such demand. (2) If proceedings resulting in refund are delayed for reasons attributable to assessee, whether wholly or in part, period of delay so attributable to him shall be excluded from period for which interest is payable, and where any question arises as to period to be excluded, it shall be decided by Chief Commissioner or Commissioner whose decision thereon shall be final...." (emphasis supplied) In Sandvik Asia Ltd. (supra), issue for consideration and determination by Supreme Court was as to whether assessee is entitled to be compensated by Revenue for delay in payment of amount due to assessee. Since there was inordinate delay in that case on part of Revenue in refunding amount, court held that assessee was entitled to be adequately compensated by way of interest for delay in payment of amount "lawfully due to assessee which are withheld wrongly and contrary to law". question as to whether assessee is entitled to interest under section 244A, when refund is against payment of self-assessment tax, had arisen before Madras High Court in case of CIT v. Cholamandalam Investment and Finance Co. Ltd. [2007] 294 ITR 438 (Mad). argument in that case revolved around question as to whether interest would be admissible under sub-section (1)(a) or sub-section (1)(b) of section 244A, this in context of distinction on account of additional requirement in former clause to effect that amount refundable must be more than 10 per cent. of tax determined. Madras High Court decided issue in favour of grant of interest to assessee under latter clause and, thus, free from aforesaid restriction. Referring to judgment of Supreme Court in Sandvik Asia Ltd. (supra), it was observed that (page 443): "... wherever assessee is entitled to refund, there is statutory liability on Revenue to pay interest on such refund on general principles to pay interest on sums wrongfully retained." In CIT v. Sutlej Industries Ltd. (supra), question of law related to interpretation of section 244(1)(b) read with Explanation appended thereto. issue was whether said clause excludes payment of interest on refund of self-assessment tax. Relying upon aforequoted observations of Supreme Court in case of Sandvik Asia Ltd. (supra) and finding support from view taken by Madras High Court in CIT v. Cholamandalam Investment and Finance Co. Ltd. (supra), Division Bench of this court, inter alia, observed that (page 338 of 325 ITR): "The tax due on returned income has to be paid by way of tax deducted at source (section 199), advance tax (section 209) or by way of self-assessment tax (section 140A). In addition, where assessment is completed at income higher than returned income, tax payable by assessee is specified in notice of demand issued under section 156 of Act. Where there is shortfall in payment of tax vis-A -vis tax finally due on assessed income, assessee is liable to pay interest under section 234B of Act. Conversely, where Revenue makes high-pitched assessment which is subsequently reduced/modified in appeal, any payment of taxes made, which are subsequently refunded as consequence of relief obtained in appeals etc., are monies legitimately belonging to taxpayers and wrongly withheld by Government. This is based on principle that if Revenue had, in first instance, made correct assessment of tax liability of assessee, assessee would not have been deprived by use of money. In such situation, where pre-paid taxes are in excess of assessed tax, assessee is entitled to refund of such tax along with interest thereon. Where assessee out of abundant caution pays self-assessment whilst staking claim in return, which claim is accepted, resulting in refund of self- assessment tax, assessee should be equally entitled to interest thereon. Section 244A was inserted in statute as measure of rationalization to ensure that assessee is duly compensated by Government, by way of payment of interest for monies legitimately belonging to assessee and wrongfully retained by Government, without any gaps. Therefore, in our view where self-assessment tax paid by assessee under section 140A is refunded, assessee should be, on principle entitled to interest thereon since self-assessment tax falls within expression'refund of any amount'." Noticeably, in case of CIT v. Sutlej Industries Ltd. (supra), assessee had paid self-assessment tax under section 140A, in addition to TDS (tax deducted at source) and advance tax. assessment order was framed under section 250 read with section 143(3) whereby refund of Rs. 66,90,474 was granted as claimed in return from out of amount earlier paid as self- assessment tax. Doubting correctness or otherwise decision in case of Sandvik Asia Ltd. (supra), Bench of two hon'ble judges of Supreme Court in case of CIT v. Gujarat Fluoro Chemicals (supra) had referred matter for consideration and authoritative pronouncement to Larger Bench. Clarifying observations in Sandvik Asia Ltd. (supra) and legal position, Larger Bench (three hon'ble judges) ruled thus (page 294 of 358 ITR): "In our considered view, aforesaid judgment has been misquoted and misinterpreted by assessee and also by Revenue. They are of view that in Sandvik case (supra) this court had directed Revenue to pay interest on statutory interest in case of delay in payment. In other words, interpretation placed is that Revenue is obliged to pay interest on interest in event of its failure to refund interest payable within statutory period. As we have already noticed, in Sandvik case (supra) this court was considering issue whether assessee who is made to wait for refund of interest for decades be compensated for great prejudice caused to it due to delay in its payment after lapse of statutory period. In facts of that case, this court had come to conclusion that there was inordinate delay on part of Revenue in refunding certain amount which included statutory interest and, therefore, directed Revenue to pay compensation for same not interest on interest. Further, it is brought to our notice that Legislature by Act No. 4 of 1988 (with effect from April 1, 1989) has inserted section 244A to Act which provides for interest on refunds under various contingencies. We clarify that it is only that interest provided for under statute which may be claimed by assessee from Revenue and no other interest on such statutory interest." (emphasis supplied) question before Supreme Court in case of Union of India v. Tata Chemicals (supra) mainly was as to whether deductor of TDS is also entitled to interest on refund of excess deduction or erroneous deduction of tax at source under section 195 of Income-tax Act. observations of Supreme Court, to extent relevant here, may be quoted verbatim as under (pages 673-74 of 363 ITR): "The refund becomes due when tax deducted at source, advance tax paid, self-assessment tax paid and tax paid on regular assessment exceeds tax chargeable for year as result of order passed in appeal or other proceedings under Act.... No interest is payable for period for which proceedings resulting in refund are delayed for reasons attributable to assessee (wholly or partly). rate of interest and entitlement to interest on excess tax are determined by statutory provisions of Act. Interest payment is statutory obligation and non-discretionary in nature to assessee.... general right exists in State to refund any tax collected for its purpose, and corresponding right exists to refund to individuals any sum paid by them as taxes which are found to have been wrongfully exacted or are believed to be, for any reason, inequitable. statutory obligation to refund carried with it right to interest also. This is true in case of assessee under Act... A'tax refund' is refund of taxes when tax liability is less than tax paid. As per old section, assessee was entitled for payment of interest on amount of taxes refunded pursuant to order passed under Act, including order passed in appeal... When collection is illegal, there is corresponding obligation on Revenue to refund such amount with interest inasmuch as they have retained and enjoyed money deposited.... There is no reason to restrict same to assessee only without extending similar benefit to resident/deductor who has deducted tax at source and deposited same before remitting amount payable to non-resident/foreign company. Providing for payment of interest in case of refund of amounts paid as tax or deemed tax or advance tax is method now statutorily adopted by fiscal legislation to ensure that aforesaid amount of tax which has been duly paid in prescribed time and provisions in that behalf form part of recovery machinery provided in taxing statute. Refund due and payable to assessee is debt- owed and payable by Revenue. Government, there being no express statutory provision for payment of interest on refund of excess amount/tax collected by Revenue, cannot shrug off its apparent obligation to reimburse deductors lawful monies with accrued interest for period of undue retention of such monies. State having received money without right, and having retained and used it, is bound to make party good, just as individual would be under like circumstances. obligation to refund money received and retained without right implies and carries with it right to interest. Whenever money has been received by party which ex ae quo et bono ought to be refunded, right to interest follows, as matter of course." (emphasis supplied) similar issue arose before High Court of Bombay in case of Stock Holding Corporation of India Ltd. v. N. C. Tewari (supra). Income-tax Appellate Tribunal in that case had held that no interest was payable under section 244A(1)(b) on refund of excess amount paid as tax on self-assessment under section 140A. assessee had filed return for assessment year 1994-95 declaring income of Rs. 13.12 crores on which tax payable was computed at Rs. 6.79 crores. Some amount had been earlier paid as advance tax and TDS credit was also claimed. To make good shortage, assessee paid Rs. 2.60 crores by way of tax on selfassessment. Assessing Officer determined income at Rs. 1.27 crores and, thus, raised further demand of Rs. 1.76 crores by way of notice under section 156. It appears that refund was due to assessee for assessment year 1995-96 and demand by notice under section 156 for assessment year 1994-95 was set off against such refund for subsequent year. assessee, in meanwhile, had brought challenge to assessment for period 1994-95 before Commissioner of Income-tax (Appeals) where refund of Rs. 2 crores was granted though interest of Rs. 18.24 lakhs from out of amount paid as self-assessment was declined. similar view was taken by Tribunal in second layer of appeal. High Court of Bombay, inter alia, held that amount paid as selfassessment tax would fall under residuary clause of section 244A(1)(b) since it is neither payment of tax by way of advance tax nor by way of tax deducted at source. court rejected contentions of Revenue that payment by way of self-assessment was gratuitous and, therefore, "not tax" and, consequently, would not attract interest. Noticing, inter alia, aforequoted observations of Supreme Court in case of Union of India v. Tata Chemicals (supra), assessee was held entitled to interest against refund Chemicals (supra), assessee was held entitled to interest against refund from out of self-assessment tax even when paid voluntarily, and not on account of deduction (as in case of Union of India v. Tata Chemicals) at higher rate in terms of order passed by tax authority, on reasoning that when assessee pays tax, either as advance tax or on self-assessment, it is paid "to discharge obligation under Act" and there is "no voluntary payment of tax on self-assessment" since noncompliance with obligations under Act visits consequences to assessee just as non-compliance with orders passed by authorities under Act would. Noticeably, Bombay High Court did not take note of clarification given by Supreme Court in CIT v. Gujarat Fluoro Chemicals (supra). In terms of procedure for assessment as contained in Chapter XIV of Income-tax Act, person in receipt of income in respect of which he is assessable under law is required to furnish return under section 139 in accordance, amongst others, with provisions of section 140. When tax is payable on basis, inter alia, of such return furnished under section 139, assessee is liable to pay such tax (together with interest for delay, if any) after taking into account amount of tax, if any already paid, tax deducted or collected at source and relief of tax or deduction of tax (section 199) if any claimed, etc. Thus, at time of furnishing return, assessee is required to engage in exercise of "self-assessment" under section 140A and pay balance liability (if any) on such computation. There are detailed provisions relating to collection and recovery of tax in Chapter XVII of Income-tax Act which include, in Part C provisions for "advance payment of tax". Section 207 declares generally liability of assessee to pay "in advance" tax during financial year in respect of total income "which would be chargeable to tax for assessment year immediately following". computation of advance tax on "current income" for such purposes is carried out in accordance with section 209, clause (a) of sub-section (1) whereof only needs to be noted as under: "where calculation is made by assessee for purposes of payment of advance tax under sub-section (1) or sub-section (2) or sub-section (5) or sub-section (6) of section 210, he shall first estimate his current income and income-tax thereon shall be calculated at rates in force in financial year." (emphasis supplied) It may be added here that clauses (b) and (c) of sub- section (1) of section 209 pertain to cases where calculation is made (not by assessee but) by Assessing Officer, while clause (d) pertains to effect of tax deductible or collectible at source, which are not relevant for present discussion. For proper understanding of method of computation of advance tax, it is necessary also to take into account provision contained in section 210, since it, inter alia, provides guidance to assessee to calculate and pay advance tax "of his own accord". "210. Payment of advance tax by assessee of his own accord or in pursuance of order of Assessing Officer.-(1) Every person who is liable to pay advance tax under section 208 (whether or not he has been previously assessed by way of regular assessment) shall, of his own accord, pay, on or before each of due dates specified in section 211, appropriate percentage, specified in that section, of advance tax on his current income, calculated in manner laid down in section 209. (2) person who pays any instalment or instalments of advance tax under sub-section (1), may increase or reduce amount of advance tax payable in remaining instalment or instalments to accord with his estimate of his current income and advance tax payable thereon, and make payment of said amount in remaining instalment or instalments accordingly. (3) In case of person who has been already assessed by way of regular assessment in respect of total income of any previous year, Assessing Officer, if he is of opinion that such person is liable to pay advance tax, may, at any time during financial year but not later than last day of February, by order in writing, require such person to pay advance tax calculated in manner laid down in section 209, and issue to such person notice of demand under section 156 specifying instalment or instalments in which such tax is to be paid. (4) If, after making of order by Assessing Officer under sub- section (3) and at any time before 1st day of March, return of income is furnished by assessee under section 139 or in response to notice under sub-section (1) of section 142, or regular assessment of assessee is made in respect of previous year later than that referred to in sub-section (3), Assessing Officer may make amended order and issue to such assessee notice of demand under section 156 requiring assessee to pay, on or before due date or each of due dates specified in section 211 falling after date of amended order, appropriate percentage, specified in section 211, of advance tax computed on basis of total income declared in such return or in respect of which regular assessment aforesaid has been made. (5) person who is served with order of Assessing Officer under sub-section (3) or amended order under sub-section (4) may, if in his estimation advance tax payable on his current income would be less than amount of advance tax specified in such order or amended order, send intimation in prescribed form to Assessing Officer to that effect and pay such advance tax as accords with his estimate, calculated in manner laid down in section 209, at appropriate percentage thereof specified in section 211, on or before due date or each of due dates specified in section 211 falling after date of such intimation. (6) person who is served with order of Assessing Officer under sub-section (3) or amended order under sub-section (4) shall, if in his estimation advance tax payable on his current income would exceed amount of advance tax specified in such order or amended order or intimated by him under sub-section (5), pay on or before due date of last instalment specified in section 211, appropriate part or, as case may be, whole of such higher amount of advance tax as accords with his estimate, calculated in manner laid down in section 209." (emphasis supplied) It is clear from bare reading of above provisions that whether for purposes of computing advance tax liability or for that matter calculation of self-assessment tax, assessee is given liberty to make estimation "of his own accord". Revenue expects proper declaration on basis of which liability would be eventually determined. After all, necessary information or data is available first to assessee. Since advance tax is paid on quarterly basis, assessee is in position to revise calculations as financial year progresses. He may increase or decrease amount to be paid as quarterly instalment of advance tax corresponding to increase or reduction of income generated. person who has already been assessed to income-tax in previous year(s) has advantage of benchmark of such earlier periods. Assessing Officer, on other hand, is also given authority by law, by virtue of section 210(3) or (4), to keep tab on payment(s) of advance tax having regard, inter alia, of income reported in preceding years and require deposit of advance tax to optimum extent. Notwithstanding this authority of Assessing Officer, for purposes of advance tax, assessee retains his discretion to compute his taxable income and tax liability of his own estimation and, thus, may deposit advance tax only to extent he concedes, thereby ignoring order of Assessing Officer as communicated in terms of section 210(3) or (4). Unlike liability towards advance tax (section 207), there is no specific provision in Income-tax Act for guiding assessee in computing his liability towards "self-assessment" (in terms of section 140A). But since, in scheme of things, liability towards "advance tax" would come up ahead of stage when assessee is required to compute tax payable finally with return, described as self-assessment, it is clear that having paid quarterly instalment of advance tax and reviewed estimate of current income at each such stage, assessee would be equipped with better information and data required to be taken into account for calculating "current income" and, thus, in better position to arrive at more accurate estimate and compute tax liability when time comes for submitting return under section 139 and calculating self- assessment tax under section 140A. declaration of taxable income or tax liability in return is subject to order of assessment required to be passed by Assessing Officer, amongst others, under section 143. There is no finality given to order of assessment at hands of Assessing Officer. There are provisions for rectification, appeal, etc. There are also provisions for dealing with income that escapes appeal, etc. There are also provisions for dealing with income that escapes assessment. When liability is determined, whether in terms of assessment order or in accordance with order passed by appellate authorities, or superior forums, if any tax, interest, penalty, fine, etc., remain due to Revenue, Assessing Officer is authorised by section 156 to require assessee to pay such sum by serving notice (or revised notice) of demand. notice of demand under section 156, if issued before assessment becomes final and binding, is subject to upward revision (or refund) in due course, in accordance with assessment that comes to be finally made. stage for refund comes when assessment attains finality. liability of Revenue to pay interest on refund of excess amount paid towards Income-tax Act by assessee, in terms of section 244A requires to be examined in above light. Concededly, provisions contained in section 115WJ (advance tax in respect of fringe benefits), section 199 (credit for tax deducted), section 206C (profits and gains from business of trading in alcoholic liquor, forest produce, scrap, etc.) or section 207 (liability for payment of advance tax) have no connection with liability to pay self-assessment tax. Therefore, clause (a) of sub-section (1) of section 244A would not apply to refund out of amount paid as selfassessment tax. Clause (b), on other hand, is residuary provision. It opens with expression "in any other case". Naturally, therefore, liability of Revenue towards interest on refund from out of amount paid as self-assessment tax would fall under this clause. Noticeably, for purposes of calculating liability of Revenue towards interest on amount being refunded under section 244A(1)(b), beginning point is prescribed as "date of payment of tax (or penalty)". This expression is defined in Explanation appended to clause to be indicative of date of payment of amount "specified" in demand notice under section 156. Thus, legislation makes it clear that for residuary clause, amount paid by assessee (from which refund is to be made) must have been deposited pursuant to demand notice issued by assessing authority. To put it conversely, clause would not apply, by virtue of Explanation, in case excess amount (being refunded) has been paid by assessee otherwise than in compliance with demand notice or voluntarily. This is import and effect of Explanation if language employed thereof is read, understood and construed in its natural and ordinary sense. Since words used are clear, plain and unambiguous, there is no scope for beneficent construction since it would lead to re-legislation, which is impermissible. observations of Supreme Court in Sandvik Asia Ltd. (supra) must be understood in light of clarification given in case of CIT v. Gujarat Fluoro Chemicals (supra). There is no liability of Revenue to pay tax on refund beyond liability created by statutory provisions. In case of Union of India v. Tata Chemicals (supra), collection of tax (through deductor) was found to be illegal, thus giving rise to liability to pay interest on refunded amount. We, thus, conclude that there cannot be general rule that whenever refund of income-tax paid in excess is to be made, Revenue must necessarily pay interest on refunded amount. letter and spirit of law on subject is that party which committed error in proper calculation (or delay in proper assessment) must bear burden. If excess amount is paid due to erroneous assessment by Revenue, having exacted such burden wrongfully and inequitably on assessee and having retained excess amount thus received, reimbursement must be accompanied by payment of interest at statutorily prescribed rate. Conversely, if assessee is to be blamed for miscalculation (or for delay or, for that matter, want of claim of refund), Revenue does not owe any interest even if excess payment of tax is liable to be refunded. Having found position of law as indicated above, we express, with respect, our inability to subscribe to, or follow, view taken by other Division Bench of this court in case of CIT v. Sutlej Industries Ltd. (supra). Even otherwise, noticeably, in case of CIT v. Sutlej Industries Ltd. (supra), question had been examined in facts and circumstances indicative of "high-pitched assessment" made by Revenue and refund of self-assessment tax resulting from claim to such effect being made by assessee in return. In case at hand, Revenue had not made excessive assessment so as to impel deposit of selfassessment tax in excess. assessee did not make claim for refund in return. Such claim appears to have come later. For very same reasons as set out above, we are not inclined to endorse view taken by Madras High Court in case of CIT v. Cholamandalam Investment and Finance Co. Ltd. (supra) wherein, in our view, proposition of law on subject was expounded in too broad terms. As clarified by Supreme Court in case of CIT v. Gujarat Fluoro Chemicals (supra), there is no general principle obliging Revenue to pay interest on all sums wrongfully retained. It is trite that fiscal statute is to be construed strictly. claim of interest on refund of income-tax has to be pegged on statutory clauses only. For foregoing reasons, we answer substantial question of law mentioned in paragraph 3 above accordingly in favour of Revenue. In absence of explanation as to how assessee erred in calculation of self-assessment tax, there being no allegation that such excess deposit was pursuant to demand by Revenue, claim for interest on excess payment voluntarily made cannot be sustained. In result, appeal is allowed and impugned order passed by Income-tax Appellate Tribunal directing Assessing Officer to pay interest to assessee on refunded amount is set aside. *** Commissioner of Income-tax v. Engineers India Ltd