BNY MELLON INTERNATIONAL OPERATIONS (INDIA) PVT LTD,PUNE vs. I.T.O , CPC BANGALURU, BANGULURU

ITA 2706/PUN/2024Status: DisposedITAT Pune26 November 2025AY 2021-2213 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal noted that the intimation under Section 143(1) merges with the assessment order under Section 143(3). Since no additions were made and the returned income was accepted, the issue of Section 234C interest was deemed infructuous. However, due to lack of clarity on the computation of interest, the matter was remitted to the AO.

What were the facts?

The assessee challenged the levy of interest under Section 234C of the Income Tax Act. The CIT(A) rejected the additional ground regarding this interest, stating it lacked jurisdiction. The assessment order under Section 143(3) accepted the returned income, making no additions.

What were the issues?

Whether interest under Section 234C is leviable when the returned income is accepted and no additions are made. Whether the CIT(A) erred in rejecting the additional ground concerning Section 234C interest due to jurisdictional reasons.

Which sections of the Income-tax Act were involved?

Section 234C,Section 143(1),Section 143(3),Section 144B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PUNE “A” BENCH : PUNE

Before: SHRI MANISH BORAD & SHRI VINAY BHAMORE

Hearing: 12.11.2025Pronounced: 26.11.2025

PER : MANISH BORAD, AM These appeals at the instance of the same assessee are directed against the separate orders ADDL/JCIT (Appeals)-4, Kolkata [“CIT(A)”] evenly dated 28/10/2024 passed u/s.250 of the Income Tax Act, 1961 (“Act”) which are arising out of assessment order passed u/s.143(3) r.w.s.144B of the Act, dated 02/12/2022 and intimation u/s.143(1) of the Act dated 26/07/2023 for the Assessment Years (AY) 2021-22 & 2022-23 respectively.

2.

As the issues raised in the instant two appeals are mostly common and pertains to the same assessee, these appeals were heard together and are being disposed of by this common order for

The order continues below.

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