CBDT IS VESTED WITH POWERS U/S 119 TI ISSUE INSTRUCTIONS AND CIRUCALARS , INSTRUCTION ISSUED , RELAXING THE TIME LIMIT FOR FILING APPLICATION FOR REFUND BUT SUBJECT TO THE CONDTION THAT ASSESS SHALL NOT DEMAND INTREST ON SUCH REFUND .
AND :- SUCH A CONDITION IS CONTRARY TO THE PROVISION OF SECTION 244A , THAT GRANTS INTEREST ON DELAYS REFUND , THERE FORE THE CONDITION THAT RAN CONTRARY TO THE STATUTE WAS FOUND TO BE INVALID
DINAKAR ULLAL V/S CIT