ANURADHA KUMARI,JAIPUR vs. DCIT, CIRCLE-6, JAIPUR

ITA 469/JPR/2023Status: DisposedITAT Jaipur10 September 2024AY 2014-15Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal noted that the assessee paid the total taxes before the due date of filing the return of income. Citing CBDT Circular No. 2/2015 and the Supreme Court judgment in CIT vs. Prannoy Roy, the Tribunal held that no interest under Section 234A would be charged on self-assessment tax paid before the due date of filing the return.

What were the facts?

The assessee filed her return of income under Section 139(4) on March 30, 2015, but paid the due taxes on July 30, 2014, which was within the due date of filing under Section 139(1). The AO charged interest under Section 234A, which was confirmed by the CIT(A).

What were the issues?

Whether interest under Section 234A is leviable when taxes are paid before the due date but the return is filed belatedly under Section 139(4).

Which sections of the Income-tax Act were involved?

Section 154(8),Section 234A,Section 139(4),Section 139(1)

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Income Tax Appellate Tribunal, JAIPUR BENCHES,”A’ JAIPUR

Before: SHRI SANDEEP GOSAIN, JM & SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA No. 469/JP/2023

Hearing: 08/08/2024Pronounced: 10/09/2024

PER: SANDEEP GOSAIN, JM This appeal filed by the assessee is directed against order of the ld. CIT(A) dated 26-05-2023, National Faceless Appeal Centre, Delhi [ hereinafter referred to as (NFAC) ] for the assessment year 2014-15 raising therein following grounds of appeal. ‘’1. In the facts and circumstances of the case and in law the ld CIT(A) has erred in holding that rejection of rectification application u/s 154 was valid even if passed beyond 06 mon

The order continues below.

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