2025 (8) TMI 838

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..../-. 2. The sole grievance of the assessee is whether interest under Section 234A can be levied for a period subsequent to the discharge of the entire self-assessment tax liability when the return of income has been filed within the extended statutory timeline granted by the CBDT. 3. The facts relevant to the issue are that the assessee, a private limited company, e-filed its return of income on 12/03/2022 declaring a total income of Rs. 7,82,40,470/-. The Centralised Processing Centre (CPC), in its intimation dated 28/03/2022 under Section 143(1), accepted the returned income in toto. However, a demand arose solely on account of interest computed under Section 234A for a period of five months from November 2021 to March 2022, notwiths....

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.... of the Act, in cases where the amount of tax on the total income as reduced by the amount as specified in clauses (i) to (vi) of sub-section (1) of that section exceeds one lakh rupees." 6. The CBDT again by Circular No. 01/2022 dated 11/01/2022 further extended the due date to 15th March 2022 reiterating the same caveat. The operative part is in the following terms: "On consideration of difficulties reported by the taxpayers and other stakeholders due to COVID and in electronic filing of various reports of audit under the provisions of the Income-tax Act, 1961 (the Act), the Central Board of Direct Taxes (CBDT) has decided to further extend the due dates for filing of Income Tax Returns and various reports of audit for the Ass....