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The Income Tax Appellate Tribunal (ITAT) ruled that when an assessee promptly computed and paid advance tax u/ss 234A, 234B, and 234C of the Income Tax Act, and an unanticipated capital gain transaction occurred in the fourth quarter, the liability to pay advance tax on the capital gain arises only after the transaction takes place. Since the assessee discharged the advance tax liability u/s 234C on March 31, 2019, after the capital gain accrued, and the department did not allege non-payment of the entire tax due, including capital gains, no interest u/s 234C was warranted. Relying on the case of M/S HAMILTON INDUSTRIES PVT. LTD., the ITAT directed the deletion of interest of Rs. 1,18,52,988/- and partially allowed the assessee's appeal.
The Income Tax Appellate Tribunal (ITAT) ruled that when an assessee promptly computed and paid advance tax u/ss 234A, 234B, and 234C of the Income Tax Act, and an unanticipated capital gain transaction occurred in the fourth quarter, the liability to pay advance tax on the capital gain arises only after the transaction takes place. Since the assessee discharged the advance tax liability u/s 234C on March 31, 2019, after the capital gain accrued, and the department did not allege non-payment of the entire tax due, including capital gains, no interest u/s 234C was warranted. Relying on the case of M/S HAMILTON INDUSTRIES PVT. LTD., the ITAT directed the deletion of interest of Rs. 1,18,52,988/- and partially allowed the assessee's appeal.
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