2023 (4) TMI 726

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....h emanated out of an order of intimation issued Dy. CIT, Bengaluru u/s 143(1) of the Act. 1. Briefly stated the facts of the case are; 1.1. The appellant is a resident individual e-filed his return of income [for short "ITR"] for AY 2020-21 on 17/10/2020 declaring total income of Rs.86,77,950/- which was e-processed u/s 143(1) of the Act computing interest u/s 234A of the Act to Rs.55,794/- for the period commencing from 01/08/2020 upto the date of filing of return as against appellant's quantification of Rs.19,183/- computed from 01/08/2020 upto the date of discharge of taxes by way of self-assessment u/s 140A of the Act. 1.2. Aggrieved by aforesaid charge of interest, the appellant assailed before Ld. FAA, wherein the Ld. NFAC vi....

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.... to the date of payment of tax. 2. The appellant craves leave to add, alter, omit or substitute any of the above grounds at the time of hearing of the appeal". 2. Undisputedly, the appellant has discharged the entire tax liability in five instalments in two months i.e. August and September, 2020 and while doing so, interest u/s 234A was computed and paid on the amount of outstanding tax liability as on the date of respective payments for the period commencing from 01/08/2020. Per contra the revenue has set up the case for recovery of interest commencing from first day after the expiry of due date of filing i.e. 01/08/2020 upto the date of return filed i.e. 17/10/2020. 3. After hearing to rival contentions, we find that, the s....