ITAT Panji says Section 28 Interest Retains the Character of Compensation

Interest awarded under Section 28 of the Land Acquisition Act is fundamentally different from interest under Section 34. Following the Supreme Court's decision in CIT v. Ghanshyam (HUF) and subsequent High Court and Tribunal rulings, ITAT held that Section 28 interest forms part of enhanced compensation and does not fall within the taxation mechanism under Sections 145A and 56(2)(viii). The Tribunal deleted the addition of ₹1.08 crore and consequentially deleted the penalty under Section 270A.