Section 234B interest must stop at 140A payment date; excess computation is a rectifiable apparent mistake.

Where tax is paid under section 140A before determination of income under section 143(1)(a) or completion of regular assessment, interest under section 234B must be computed only up to the date of such payment and reduced by any interest already paid under section 140A. Charging interest beyond that period is a mistake apparent from the record and can be rectified under section 154. The assessee's returned income was ultimately accepted without addition, so the incorrect interest computation was held amendable by rectification, and the appeal was allowed.

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Issues: Whether the computation of interest under section 234B was required to be restricted up to the date of payment of tax under section 140A and whether the resulting mistake in the intimation could be rectified under section 154.

Analysis: The assessee had paid tax under section 140A before the date of determination of total income under section 143(1)(a) and the returned income was ultimately accepted without addition in the regular assessment under section 143(3). On the plain terms of section 234B(2)(i), where tax is paid before such determination or completion of regular assessment, interest has to be calculated up to the date of payment and reduced by any interest already paid under section 140A. In these circumstances, the charging of interest beyond the permissible period was a mistake apparent from the record and was amenable to rectification.

Conclusion: The computation of interest under section 234B was erroneous and liable to be rectified under section 154. The appeal was allowed in favour of the assessee.

Final Conclusion: The assessee succeeded on the rectification issue, and the interest levy was confined to the period permitted by law, resulting in allowance of the appeal.

Ratio Decidendi: Where tax is paid under section 140A before determination of income under section 143(1)(a) or completion of regular assessment, interest under section 234B must be computed only up to the date of such payment, and an incorrect computation contrary to that mandate constitutes a rectifiable apparent mistake.

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