MANU VYAPAR PRIVATE LIMITED,KOLKATA vs. ITO, WARD 4(1), KOLKATA

ITA 792/KOL/2026Status: DisposedITAT Kolkata18 August 2026AY 2021-20224 pages
AI SummaryAllowed

What were the facts?

The assessee, a Non-Banking Finance Company, filed its return of income for AY 2021-22 on 18.02.2022. The CPC processed the return and charged interest under sections 234A, 234B, and 234C. The assessee's rectification applications were dismissed, and the CIT(A) also dismissed its appeal.

What did the Tribunal hold?

The Tribunal held that the assessee filed its return within the extended due date due to COVID-19. Therefore, levying interest under sections 234A, 234B, and 234C was erroneous. The Tribunal directed the CPC to consider the MAT credit for calculating interest liability.

What were the issues?

Whether interest under sections 234A, 234B, and 234C was correctly levied when the return was filed within the extended due date due to COVID-19? Whether MAT credit should be considered for calculating interest liability?

Which sections of the Income-tax Act were involved?

Section 234A,Section 234B,Section 234C,Section 115JAA,Section 139(1),Section 143(1),Section 154,Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “C” BENCH,

Before: SHRI YOGESH KUMAR U.S. & SHRI RAKESH MISHRA

For Appellant: Shri Anup Sanghai, AR
For Respondent: Shri Rishikesh Pandey, Sr. DR
Hearing: 11.08.2026Pronounced: 18.08.2026

PER YOGESH KUMAR U.S., JUDICIAL MEMBER:

This Appeal is filed by the Assessee against the order of the Commissioner of Income Tax (Appeal) (‘Ld. CIT(A)’ for short) dated 05.01.2026, passed u/s 250 of the Income Tax Act, 1961 (“the Act”, for short) for the Assessment Year 2021-22. 2. Brief facts of the case are that, Assessee is a Non-Banking Finance Company filed its return of income for the assessment year 2021-22 passed u/s 139(1) of the Act on 18.02.2022 declaring total income of Rs.2,03,82,390/-. The return of the Assessee has been processed by CPC, Bengaluru and raised a demand amounting to Manu Vyapar Private Limited; A.Y: 2021-22 Rs.1,31,430/- vide passing Intima

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 234A

All 5,064 judgments and leading authorities on Section 234A →

Recent GST High Court judgments

Search GST case law →