2026 (9) TMI 1533

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....e Assessment Year 2021-22. 2. The Assessee raised the following grounds of appeal : "1. The Order under section 250 of the Act, dated 18/12/2025, passed by the CIT(A), Chennai -18, is contrary to the law and the facts passed without the jurisdiction, is passed in violation of the principles of Natural Justice. 2. The computation of the interest under Section 234A of the Act was never recorded either in the Assessment Order or in the computation sheet and hence this issue would not form part of the "Record" under Section 154 of the Act. 3. Since there was no record of the computation of Interest under Section 234A of the Act, such issue cannot be "apparent" as per Section 154 of the Act. The CIT(A) failed to est....

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....iled the return of income belatedly under the provisions of section 139(4) of the Act on 23.05.2022 for the Assessment Year 2021-22 disclosing a total income at Rs. 16,42,820/-. Subsequently, search and seizure operations were conducted u/s. 132 of the Income Tax Act, 1961 in the case of husband of the appellant on 27.11.2020. Against the said return of income, the assessment was completed by the ACIT, Central Circle-1(4), Chennai (hereinafter called AO') vide order dated 24.09.2022 passed u/s. 143(3) of the Act at total income of Rs. 46,24,465/-. While doing so, the Assessing Officer made addition of Rs. 29,81,644/- on account of credits in the bank account as unexplained money of the appellant. Subsequently, the Assessing Officer issued n....

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.... Learned Sr. DR submits that the grievance of the appellant had already been addressed by the Learned CIT(A) by reducing the period of levy of interest from 10 months to 8 months. She further submits that levy of interest for shorter period u/s. 234A constitute a mistake apparent from the record. The decision of the Hon'ble Delhi High Court in the case of Hotz Hotels Vs. CIT [2011] 118 Taxman 94 (Del) is distinguishable on the facts. 7. We heard rival submissions and perused the material available on record. The issue that arises for our consideration is the reckoning of the period for which interest is leviable u/s. 234A of the Income Tax Act. The assessment year involved is 2021-22 the due date for filing the return of income u/s. 139(....