Following the finality of the proceedings, the appellant sought refund of the amount deposited during investigation. The appellant challenged only the rate of interest, seeking 12% interest on the delayed refund. It was submitted that the Calcutta High Court had categorically held that, in the absence of a statutory provision prescribing the rate of interest applicable to refund of amounts deposited during investigation, interest at 12% was payable. Accordingly, the Tribunal concluded that the appellant was entitled to interest at 12% on the refund of the amount deposited during investigation. As the amount deposited during investigation was retained without authority of law, the Appellant prayed for refund of the amount deposited along with interest @12%.