Case of PCIT vs HCL Infotech Pvt Ltd, HC Delhi Judgement Dated 10th February 2026. At the outset, the court accepted the stated reasons delay of 690 days in re-filing the appeal and condoned the delay. HC noted that interest on refund under Section 244A is ordinarily payable as a matter of course and may be denied only in exceptional circumstances where the delay is attributable to the assessee. It also noted that the statute specifically assigns the authority to determine the period of delay attributable to the assessee to higher authorities such as the PCCIT/ CCIT/ CIT. HC thus, ruled that an Assessing Officer (AO) cannot unilaterally decide whether a delay in processing a tax refund is attributable to taxpayer and allowed interest on TDS refund.