EKATAA COMMERCIAL CENTRE PRIVATE LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 3, MUMBAI

ITA 4902/MUM/2025Status: DisposedITAT Mumbai12 March 2026AY 2021-22Bench: SHRI OM PRAKASH KANT (Accountant Member), SHRI SANDEEP SINGH KARHAIL (Judicial Member)1 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that the assessee is entitled to a reduction in interest under Section 220(2) as the assessed income was reduced. However, it disagreed with computing the interest from the date of the rectification order. The issue of recomputation of interest was restored to the AO for fresh assessment.

What were the facts?

The assessee filed its return, which was processed under Section 143(1), accepting the returned income. Subsequently, following settlement of appeals under the Vivad Se Vishwas Scheme, a rectification order under Section 154 revised the assessed income. The Assessing Officer levied interest under Section 220(2) on the demand arising from the revised income.

What were the issues?

Whether interest under Section 220(2) should be computed on the revised assessed income and from which date.

Which sections of the Income-tax Act were involved?

Section 250,Section 154,Section 220(2),Section 234C,Section 139(4),Section 143(1),Section 156

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “E” BENCH, MUMBAI

Before: SHRI OM PRAKASH KANT & SHRI SANDEEP SINGH KARHAIL

For Appellant: Shri Suyog Bhave a/w. Shri Kshitij Kasi
For Respondent: Shri Hemanshu Joshi Sr. DR

PER SANDEEP SINGH KARHAIL, J.M.

The assessee has filed the present appeal against the impugned order dated 12.06.2025, passed under section 250 of the Income Tax Act, 1961 (“the Act”) by the learned Commissioner of Income Tax (Appeal) – 53, Mumbai [“learned CIT(A)”], which in turn arose from the order passed under section 154 of the Act, for the assessment year 2021-22. 2. In this appeal, the assessee has raised the following grounds: - “1. The Ld. CIT (Appeals) on the facts and circumstances of the case and in law has erred in upholding interest u/s 220 of

The order continues below.

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