Loading judgment…
Facts
The assessee filed an appeal against the order of the Ld. Addl. / JCIT(A), Thane, who confirmed the addition/adjustment of higher interest under sections 234A, 234B, and 234C made by the CPC, Bengaluru. The assessee contended that the CPC had erroneously computed the interest up to the date of processing of the Income Tax Return (ITR-U) instead of the date of filing the return.
Held
The Tribunal, after considering the submissions from both sides, decided to remand the matter back to the Assessing Officer. The AO was directed to verify the assessee's claim as per law and make necessary adjustments of interest after providing due and adequate opportunity of hearing to the assessee.
Key Issues
Whether the CIT(A) erred in confirming the interest addition under sections 234A, 234B, and 234C, when the interest was calculated by the CPC up to the ITR processing date instead of the filing date.
Sections Cited
234A, 234B, 234C
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, CHANDIGARH BENCH, ‘A’, CHANDIGARH
Before: SHRI LALIET KUMAR & SHRI KRINWANT SAHAY
Order Per Krinwant Sahay, AM : Appeal in this case has been filed by the assessee against the order dated 18.08.2025 passed by the Ld. Addl. / JCIT(A), Thane.
Grounds of appeal, as raised by the Assessee are reproduced as under:
1. 1. 1. 1. 1. 1. 1300-Chd-2025 2 1.1 That the Ld. CIT(A) has erred in confirming the addition/adjustment of higher amount interest u/s 234A, 2348 and 234C as made by the CPC, Bengaluru against the interest disclosed by the assessee while filing ITR- U. 1.2 That the CIT(A) has erred in not considering the fact that the CPC, Bengaluru have computed interest upto the date of processing of the Income Tax Return and not upto the date of filing of such return.
2. That the appellant craves leave to add or amend the grounds of appeal before the appeal is finally heard or disposed off.
5. At the very outset, the ld. Counsel of the Assessee submitted before the Bench that the Ld. CIT(A) has confirmed the addition / adjustment of higher amount interest u/s 234A, 234B and 234C, as made by the CPC Bangaluru against the interest disclosed by the Assessee while filing ITR-U. It has further been submitted that the Ld. CIT(A) has not taken into consideration the fact that the CPC has computed the interest upto the date of processing of I.T. Return and not upto the date of filing of such return and as such the confirmation of addition by the Ld. CIT(A) is not in order. A prayer has been made to 1300-Chd-2025 3 remand the matter back to the lower authorities for deciding the matter as per law.
Per contra, ld. DR relied on the orders of the authorities below.
We have considered the findings given by the authorities below and the submissions as well as arguments of the ld. DR. We are of this considered view that in the fitness of things, the matter should be remanded back to the file of the Assessing Officer with a direction to verify the claim of the Assessee as per law and making adjustment of interest after giving due and adequate opportunity to the Assessee as required under the law.
Accordingly, the case is remanded back to the file of the AO for adjudication afresh on merit, by considering the submissions, documentary evidence produced by the Assessee and the relevant material available on record. Needless to say, that the Assessing Officer shall afford due, reasonable and adequate opportunity of hearing to the Assessee. The Assessee, no doubt, shall cooperate in 1300-Chd-2025 4 the proceedings before the Assessing Officer. All pleas available under the law shall remain so available to the assessee. Ordered accordingly.
In the result, Assessee’s appeal is allowed for Statistical Purposes.
Order Pronounced on 13.2.2026.