INCOME TAX : On interplay of sections 244A(1A) and 153(5), interest under section 244A(1A) would not accrue in cases of fresh assessment and use of words 'wholly or partly' therein only indicate that bar on interest accrual is confined only to that part of assessment that are occasioned by remittance/remand and would not extend to other concluded issues that give rise to refund under section 153(5). Thus, section 244A(1A) would apply to cases where on certain issues,
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