TaxTMI 
TaxTMI 
2026 (9) TMI 1802
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....-26. The impugned order arises from the intimation dated 02.04.2025 issued by the Assistant Commissioner of Income-tax, Centralized Processing Cell-TDS ["AO"], under section 200A of the Act in respect of Form No. 26QB for the financial year 2024-25. 2. The assessee has raised the following grounds of appeal: 1. On the facts and in the circumstances of the appellant's case and in law, the Ld. Commissioner of Income Tax (Appeals) erred in confirming the levy of interest amounting to Rs 21,144/- imposed by the Ld. Assessing Officer u/s 201 of the Income Tax Act, 1961, without appreciating the fact that the appellant had substantially complied with the statutory provisions in good faith, and that the levy of such interest is unjusti....
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....corded in the order of the learned CIT(A), the entire consideration was paid to the seller on 08.08.2024, while the sale deed was executed and the property was registered in the name of the assessee on 08.10.2024. 4. The assessee subsequently deposited TDS amounting to Rs. 1,76,250/- and furnished the challan-cum-statement in Form No. 26QB on 29.03.2025. The Form No. 26QB was processed by the CPC-TDS under section 200A of the Act. By the intimation dated 02.04.2025 the AO charged interest of Rs. 21,144/- under section 201(1A) of the Act for delayed payment of TDS and levied fee of Rs. 36,000/- under section 234E of the Act for delayed furnishing of Form No. 26QB. After rounding off, the net demand was determined at Rs. 57,140/-. 5. Ag....
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.... Authorised Representative reiterated the submissions made before the learned CIT(A). He submitted that the delay in depositing the TDS and furnishing Form No. 26QB was neither deliberate nor wilful, but occurred on account of the assessee's lack of awareness regarding the prescribed timelines and the temporary unavailability of his accountant owing to medical exigencies in the latter's family. Upon noticing the lapse, the assessee deposited TDS of Rs. 1,76,250/- and furnished Form No. 26QB on 29.03.2025. The learned AR further submitted that the tax was deposited, and credit thereof was made available to the deductee, within the same financial year, resulting in no loss to the Revenue. It was contended that the assessee had substantially c....
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....present case, the assessee has not disputed the delay in depositing the TDS. The explanation concerning lack of awareness of the statutory timeline and the unavailability of the accountant may explain the circumstances in which the delay occurred, but it does not extinguish the statutory liability to interest under section 201(1A). The plea that the tax was deposited within the same financial year or that the deductee ultimately received credit for the tax also does not alter the admitted fact that the amount was not deposited within the prescribed period. Compliance within the same financial year cannot substitute compliance within the time specifically prescribed under the Act and the Rules. 11. Interest under section 201(1A) compensat....