2026 (6) TMI 472

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....earned Addl./Joint CIT(A)"], which in turn arose from the intimation issued under section 143(1) of the Act, for the assessment year 2020-21. 2. In this appeal, the assessee has raised the following grounds: - "I. INTEREST UNDER SECTION 234A, 234B AND 234C OF THE ACT: ITA No. 1070/Mum/2026 (A.Y. 2020-21) 2 1.1 On the facts and in circumstances of the case and in law, the learned Commissioner of Income-Tax (Appeals) [CIT(A)], erred in confirming interest charged under the provisions of Section 234A, 234B and 234C of the Act, while processing the Return of Income under Section 143(1) of the Act by the learned Assistant Director of Income Tax (CPC) (The Assessing Officer), (hereinafter referred to as "the AO"). 1.....

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....dividend income in the month of March 2020 and hence, could not pay advance tax in respect of such dividend income prior to 15.03.2020. The learned Addl./Joint CIT(A), vide impugned order, dismissed the appeal filed by the assessee and held that the assessee did not pay the entire tax liability arising on account of dividend received by it on 09.03.2020 by the time provided under 1st proviso to section 234C of the Act. Accordingly, the learned Addl. / Joint CIT(A) upheld the levy of interest under section 234C of the Act. Being aggrieved, the assessee is in appeal before us. 5. During the hearing, the learned Authorised Representative ("learned AR") submitted that the assessee, during the relevant financial year, i.e., 2019-20, paid adva....

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....(1) of the Act, since the assessee filed the return of income on 29.09.2020, the interest was computed under section 234A of the Act for a period of two months. 6. On the other hand, the learned Departmental Representative ("learned DR") vehemently relied upon the order passed by the learned Addl./Joint CIT(A). 7. We have considered the submissions of both sides and perused the material available on record. At the outset, it is evident that there is no dispute amongst the parties regarding the fact that interest under section 234A and section 234C of the Act is leviable in the present case. However, as vide intimation issued under section 143(1) of the Act, the interest under the aforesaid sections was levied at a higher amount, the a....