CIT v. Pranoy Roy

309 ITR 231Supreme Court of India2009#2854 most cited

What is CIT v. Pranoy Roy authority for?

Interest under Section 234A, being compensatory, is not leviable on self-assessment tax paid before the due date for filing the return of income. It ceases once the tax liability is fully discharged, as there is no basis to levy interest for any subsequent period.

42

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2010 to 2025.

Also referred to as

CIT v. Pranoy Roy · Pranoy Roy SC · Section 234A interest · compensatory interest · self-assessment tax · tax paid before due date · Section 139(1) · CBDT Circular 2/2015 · interest for delay in filing return · discharge of tax liability

Also reported as

179 Taxmann 53

Sections most often in play

Section 234BSection 139(1)Section 143(1)Section 153ASection 234ASection 132(4)Section 132B(1)Section 234B(2A)

Issues it is cited on

compensatory interestsection 140asection 243section 89section 262section 2(40)section 115jaasection 208section 210section 140section 10(1)section 90a

Judgments citing CIT v. Pranoy Roy

ASHOK CHATURVEDI,DELHI vs. DCIT, CENTRAL CIRCLE-2, NOIDA

In the result, the appeal of the assessee is allowed

ITA 5156/DEL/2025[2021-22]Status: DisposedITAT Delhi23 Dec 2025AY 2021-22

Bench: Shri Vimal Kumar & Ms Renu Jauhriashok Kumar Chaturvedi, Vs. Dcit, 305, 3Rd Floor, Pamposh Central Circle-2, Enclave, Greater Kailash- Noida 1, New Delhi (Appellant) (Respondent) Pan: Aacpc1661P

For Appellant: Shri Vir Sain Agarwal, AdvFor Respondent: Ms. Ankush Kalra, Sr. DR
Section 139(1)Section 143(1)Section 234ASection 234A(1)Section 250(6)

…9.01.2022 before the extended due date of filing the return of income i.e. 15th March 2022 contrary to guidelines issued by CBDT vide Circular no. 2/2015 dated 10th February, 2015 read with judgment of Hon'ble Supreme court in the Case of CIT Vs. Prannoy Roy, 309 ITR 231 (2009). 3. That the Lower authorities are wrong on fact and bad in law in charging the interest u/s 234A of the Act which is compensatory in nature and not a penalty for delay in filing return of income u/s 139(1) of the Act. 4. The appellant craves leave to add, alter, amend or withdraw any of the grounds of appeal at the time of hearing.” 3. B…

GVR ASHOKA CHENNAI CORR LIMITED,CHENNAI vs. ADIT, BENGALURU

In the result, the appeal of the assessee is allowed

ITA 2621/CHNY/2025[2021-22]Status: DisposedITAT Chennai10 Dec 2025AY 2021-22

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunatha

For Appellant: Mr. Dharan V. Gandhi, ARFor Respondent: 20.11.2025
Section 140A(1)Section 143(1)Section 234A

…est under section 234A being compensatory in nature cannot be levied for March 2022 when no tax remained unpaid as on 01.03.2022. He further submitted that CBDT Circular No. 2/2015 and the judgment of the Hon’ble Supreme Court in Prannoy Roy & Anr. vs. CIT (309 ITR 231) clearly hold that interest under section 234A cannot be levied on self-assessment tax paid before the due date of filing of return. Hence, levy beyond the actual period of default is contrary to the statutory scheme and settled judicial principles. Therefore, the ld.AR pleaded that interest under section 234A is chargeable only on the amount o…

SUNIL KUMAR AGARWAL,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, JAIPUR

ITA 521/JPR/2025[2020-21]Status: DisposedITAT Jaipur14 Oct 2025AY 2020-21

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, \nvk;dj vihy la-@ITA Nos.513 & 519 to 521/JP/2025\nfu/k Zkj.k o\"kZ@Assessment Years : 2016-17 & 2018-19 to 2020-21\n\nSunil Kumar Agarwal\n395, Narnoli Mansion, Outside\nSanganeri Gate, Jaipur\ncuke\nVs.\nACIT,\nCentral Circle-2,\nJaipur\nLFkk;h y s[kk l a-@thvkb Zvkj la-@PAN/GIR No.: ABRPA9601M\nvihykFkhZ@Appellant i zR;Fkh Z@Respondent\n\nvk;dj vihy la-@ITSS No. 03/JP/2025\nfu/k Zkj.k o\"kZ@Assessment Year : 2015-16\

For Appellant: Shri S. L. Poddar, AdvFor Respondent: Mrs. Anita Rinesh, JCIT, Sr-DR
Section 132Section 139Section 153ASection 234B

…ic\nIt is a settled legal position that interest under Sections 234B and 234C is\ncompensatory in nature and mandatory, as held by the Hon'ble Supreme Court in:\nCIT v. Anjum M.H. Ghaswala (252 ITR 1),\nCIT v. Bhai Himat Singh (276 ITR 527).\nand Prannoy Roy (309 ITR 231).\nIn absence of valid advance tax payment, interest is automatic and not open to\nwaiver or discretion by the AO or appellate authorities except in prescribed\ncircumstances, which are not satisfied in this case.\nEven date of search and calculation of advance tax vis-à-vis with income is also\nvital. I. Legal Impact of Search on Determination o…

SUNIL KUMAR AGARWAL,JAIPUR vs. ACIT, CEN. CIR-2, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 513/JPR/2025[2016-17]Status: DisposedITAT Jaipur14 Oct 2025AY 2016-17
For Appellant: Shri S. L. Poddar, AdvFor Respondent: Mrs. Anita Rinesh, JCIT, Sr-DR
Section 132Section 139Section 153ASection 234B

…tomatic It is a settled legal position that interest under Sections 234B and 234C is compensatory in nature and mandatory, as held by the Hon'ble Supreme Court in: CIT v. Anjum M.H. Ghaswala (252 ITR 1), CIT v. Bhai Himat Singh (276 ITR 527). and Prannoy Roy (309 ITR 231). In absence of valid advance tax payment, interest is automatic and not open to waiver or discretion by the AO or appellate authorities except in prescribed circumstances, which are not satisfied in this case. Even date of search and calculation of advance tax vis-à-vis with income is also vital. I. Legal Impact of Search on Determination of Und…

SUDHIR APPUKUTTAN PANIKASSERY ,MUMBAI vs. INCOME TAX OFFICER CIRCLE 3, KALYAN

In the result, the appeal of the assesse bearing ITA No

ITA 3558/MUM/2025[2022-23]Status: DisposedITAT Mumbai03 Sept 2025AY 2022-23

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: Shri Parag VyasFor Respondent: Ms. Kavitha Kaushik (SR DR)
Section 115JSection 139Section 139(1)Section 140ASection 140B(4)Section 143(1)Section 234BSection 234FSection 250Section 89

….AO. Being aggrieved, assessee filed an appeal before us. 4. The Ld.AR filed a paper book containing pages 1 to 233, which is kept on record and respectfully relied on the orders of Hon’ble Supreme Court and High Court in the case of – (1) CIT vs Pranoy Roy – 309 ITR 231 (SC); (2) CIT vs Bangalore Animal Food Corporation Ltd 194 ITR 242 (Kar) (3) Order of Hon’ble Supreme Court in Bahi Jaspal Singh & Another vs ACIT (2011) 1 SCC 39 5. The Ld.DR argued and stands in favour of the order of revenue authorities. 6. We have heard the rival submissions and carefully perused the documents available on record. On examina…

HIND ELASTOMERS PRIVATE LIMITED,MUMBAI vs. DCIT-5(1)(1), MUMBAI

In the result, appeal of the assessee is allowed

ITA 2449/MUM/2025[2021-22]Status: DisposedITAT Mumbai11 Aug 2025AY 2021-22

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 139Section 143(1)Section 234A

…er Section 234A up to that date. Thereafter, there was no outstanding tax upon which further interest could accrue. This position is well settled. CBDT Circular No. 2/2015, issued in the wake of the judgment of the Hon’ble Supreme Court in CIT v. Prannoy Roy (309 ITR 231), clarifies that no interest under Section 234A is chargeable on self-assessment tax paid before the due date of filing the return of income. 9. Once the tax liability on which interest is to be computed stands fully discharged, there is no statutory mandate to levy interest for any subsequent period. The legislative intent and the CBDT’s own cla…

TRISIGMA APEX SERVICES LLP,NEW DELHI vs. DCIT CIRCLE 49(1), NEW DELHI

In the result, the Appeal filed by the Assessee stands allowed in the aforesaid manner

ITA 3148/DEL/2024[2021-22]Status: DisposedITAT Delhi20 Nov 2024AY 2021-22

Bench: Shri Shamim Yahya & Shri Vimal Kumara.Yr. : 2021-22 Trisigma Apex Services Llp, Vs. Dcit, Circle 49(1), 01-0103, C-Block, Community New Delhi Centre, Imperial Tower, Civic Centre, Naraina Industrial Estate, New Delhi South West, New Delhi – 28 (Pan: Aahft4549G) (Appellant) (Respondent)

For Appellant: Sh. Atul Ninawat, CAFor Respondent: Shri Amit Katoch, Sr. DR
Section 234Section 234ASection 234iSection 250

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “H”, NEW DELHI BEFORE SHRI SHAMIM YAHYA, ACCOUNTANT MEMBER, AND SHRI VIMAL KUMAR, JUDICIAL MEMBER A.YR. : 2021-22 TRISIGMA APEX SERVICES LLP, VS. DCIT, CIRCLE 49(1), 01-0103, C-BLOCK, COMMUNITY NEW DELHI CENTRE, IMPERIAL TOWER, CIVIC CENTRE, NARAINA INDUSTRIAL ESTATE, NEW DELHI SOUTH WEST, NEW DELHI – 28 (PAN: AAHFT4549G) (APPELLANT) (RESPONDENT) Appellant by : Sh. Atul Ninawat, CA Respondent by : Shri Amit Katoch, Sr. DR. Date of hearing : 12.11.2024 Date of pronouncement : 20.11.2024 ORDER PER SHAMIM YAHYA, AM : The Assessee has filed the instant Appeal ag…

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

In the result, the appeal of the assessee is allowed with no orders as to cost

ITA 469/JPR/2023[2014-15]Status: DisposedITAT Jaipur10 Sept 2024AY 2014-15

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Rohan SoganiFor Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR
Section 139Section 139(1)Section 139(4)Section 154Section 154(8)Section 234A

…efore the due date of filing of 4 SMT ANURADHA KUMARI VS ACIT, CIRCLE-6, JAIPUR return of income. On going through the said circular the Bench noticed that said Circular was issued after the judgement of Hon’ble Supreme Court in the case of CIT vs Prannoy Roy 309 ITR 231 (2009) that the interest u/s 234A on default of furnishing of return of income shall be payable only on the amount of tax which has not been deposited before the due date of filing of return of income for the relevant assessment year. Since undisputedly, the appellant has duly paid taxes amounting to Rs. 60,97,300/- on 30-07-2014 which is also ev…

SMT.RAMANI.RADHAKRISHNAN,ERNAKULAM vs. THE ACIT CENTRAL CIRCLE 2, ERNAKULAM

ITA 219/COCH/2023[2009-10]Status: DisposedITAT Cochin12 Aug 2024AY 2009-10

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Shri Mathew Joseph, CAFor Respondent: Smt. V. Swarnalatha, Sr. D.R
Section 250

…ble. Two, we may clarify that the nature of levy as mandatory, as well as compensatory, and of the default being a continuing one, is not in dispute, so that demand, where paid, would automatically close the interest, even as found in CIT v. Pranoy Roy [2009] 309 ITR 231 (SC). The compensatory aspect, which also prevailed with the Apex Court in Modi Industries Ltd. (supra), stands met by the extant law providing for interest up to the date of grant of interest; a statutory confirmation of the interest being compensatory. The dispute concerns only the aspect of ‘date of regular assessment’ in the given facts and c…

SMT.RAMANI.RADHAKRISHNAN,ERNAKULAM vs. THE ACIT CENTRAL CIRCLE 2, ERNAKULAM

ITA 218/COCH/2023[2008-09]Status: DisposedITAT Cochin12 Aug 2024AY 2008-09

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Shri Mathew Joseph, CAFor Respondent: Smt. V. Swarnalatha, Sr. D.R
Section 250

…ble. Two, we may clarify that the nature of levy as mandatory, as well as compensatory, and of the default being a continuing one, is not in dispute, so that demand, where paid, would automatically close the interest, even as found in CIT v. Pranoy Roy [2009] 309 ITR 231 (SC). The compensatory aspect, which also prevailed with the Apex Court in Modi Industries Ltd. (supra), stands met by the extant law providing for interest up to the date of grant of interest; a statutory confirmation of the interest being compensatory. The dispute concerns only the aspect of ‘date of regular assessment’ in the given facts and c…

SMT.RAMANI.RADHAKRISHNAN,ERNAKULAM vs. THE ACIT CENTRAL CIRCLE 2, ERNAKULAM

ITA 217/COCH/2023[2005-06]Status: DisposedITAT Cochin12 Aug 2024AY 2005-06

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Shri Mathew Joseph, CAFor Respondent: Smt. V. Swarnalatha, Sr. D.R
Section 250

…ble. Two, we may clarify that the nature of levy as mandatory, as well as compensatory, and of the default being a continuing one, is not in dispute, so that demand, where paid, would automatically close the interest, even as found in CIT v. Pranoy Roy [2009] 309 ITR 231 (SC). The compensatory aspect, which also prevailed with the Apex Court in Modi Industries Ltd. (supra), stands met by the extant law providing for interest up to the date of grant of interest; a statutory confirmation of the interest being compensatory. The dispute concerns only the aspect of ‘date of regular assessment’ in the given facts and c…

SANTHIMADAM AGROFARM TRUST,KOCHI vs. THE ACIT CENTRAL CIRCLE 2, KOCHI

In the result, the appeals filed by the assessee are partly allowed for statistical purposes

ITA 223/COCH/2023[2008-09]Status: DisposedITAT Cochin06 Aug 2024AY 2008-09

Bench: Shri Chandra Poojari & Shri Soundararajan K.

For Appellant: Shri Mathew Joseph, CAFor Respondent: Shri Ilaiyaraja K.S., Sr. DR
Section 132Section 142(1)Section 153CSection 194CSection 234ASection 40Section 68Section 69

…ble. Two, we may clarify that the nature of levy as mandatory, as well as compensatory, and of the default being a continuing one, is not in dispute, so that demand, where paid, would automatically close the interest, even as found in CIT v. Pranoy Roy [2009] 309 ITR 231 (SC). The compensatory aspect, which also prevailed with the Apex Court in Modi Industries Ltd. (supra), stands met by the extant law providing for interest up to the date of grant of interest; a statutory confirmation of the interest being compensatory. The dispute concerns only the aspect of ‘date of regular assessment’ in the given facts and c…

SANTHIMADAM AGROFARM TRUST,KOCHI vs. THE ACIT CENTRAL CIRCLE 2, KOCHI

In the result, the appeals filed by the assessee are partly allowed for statistical purposes

ITA 222/COCH/2023[2007-08]Status: DisposedITAT Cochin06 Aug 2024AY 2007-08

Bench: Shri Chandra Poojari & Shri Soundararajan K.

For Appellant: Shri Mathew Joseph, CAFor Respondent: Shri Ilaiyaraja K.S., Sr. DR
Section 132Section 142(1)Section 153CSection 194CSection 234ASection 40Section 68Section 69

…ble. Two, we may clarify that the nature of levy as mandatory, as well as compensatory, and of the default being a continuing one, is not in dispute, so that demand, where paid, would automatically close the interest, even as found in CIT v. Pranoy Roy [2009] 309 ITR 231 (SC). The compensatory aspect, which also prevailed with the Apex Court in Modi Industries Ltd. (supra), stands met by the extant law providing for interest up to the date of grant of interest; a statutory confirmation of the interest being compensatory. The dispute concerns only the aspect of ‘date of regular assessment’ in the given facts and c…

SANTHIMADAM AGROFARM TRUST,KOCHI vs. THE ACIT CENTRAL CIRCLE 2, KOCHI

In the result, the appeals filed by the assessee are partly allowed for statistical purposes

ITA 221/COCH/2023[2006-07]Status: DisposedITAT Cochin06 Aug 2024AY 2006-07

Bench: Shri Chandra Poojari & Shri Soundararajan K.

For Appellant: Shri Mathew Joseph, CAFor Respondent: Shri Ilaiyaraja K.S., Sr. DR
Section 132Section 142(1)Section 153CSection 194CSection 234ASection 40Section 68Section 69

…ble. Two, we may clarify that the nature of levy as mandatory, as well as compensatory, and of the default being a continuing one, is not in dispute, so that demand, where paid, would automatically close the interest, even as found in CIT v. Pranoy Roy [2009] 309 ITR 231 (SC). The compensatory aspect, which also prevailed with the Apex Court in Modi Industries Ltd. (supra), stands met by the extant law providing for interest up to the date of grant of interest; a statutory confirmation of the interest being compensatory. The dispute concerns only the aspect of ‘date of regular assessment’ in the given facts and c…

SANTHIMADAM AGROFARM TRUST,KOCHI vs. THE ACIT CENTRAL CIRCLE 2, KOCHI

In the result, the appeals filed by the assessee are partly allowed for statistical purposes

ITA 220/COCH/2023[2005-06]Status: DisposedITAT Cochin06 Aug 2024AY 2005-06

Bench: Shri Chandra Poojari & Shri Soundararajan K.

For Appellant: Shri Mathew Joseph, CAFor Respondent: Shri Ilaiyaraja K.S., Sr. DR
Section 132Section 142(1)Section 153CSection 194CSection 234ASection 40Section 68Section 69

…ble. Two, we may clarify that the nature of levy as mandatory, as well as compensatory, and of the default being a continuing one, is not in dispute, so that demand, where paid, would automatically close the interest, even as found in CIT v. Pranoy Roy [2009] 309 ITR 231 (SC). The compensatory aspect, which also prevailed with the Apex Court in Modi Industries Ltd. (supra), stands met by the extant law providing for interest up to the date of grant of interest; a statutory confirmation of the interest being compensatory. The dispute concerns only the aspect of ‘date of regular assessment’ in the given facts and c…

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1(4), CHURCHGATE MUMBAI vs. SHUBHENDU AMITABH, DELHI

In the result the appeal of the revenue is dismissed

ITA 3300/MUM/2023[2010-11]Status: DisposedITAT Mumbai30 Jul 2024AY 2010-11

Bench: Shri Amarjit Singh & Shri Sunil Kumar Singh, Juducial Member

For Appellant: Shri Rajiv Khandelwal, CA & Shri Akash KumarFor Respondent: Shri B. Laxmi Kanth, Sr. DR
Section 132(4)Section 139(1)Section 154Section 234BSection 245CSection 245D(4)

…,887 249,996,270 3. I request you to kindly adjust cash seized of Rs. 249,996,270/- against above tax kiability. Thanking you Yours faithfully, (Shubhendu Amitabh) 11. We have also perused decision of Hon’ble Supreme Court in the case of CIT vs Pranoy Roy 309 ITR 231 (SC) wherein held that since tax due has already been paid which was not less than tax payable on returned income which was accepted, question of levy of interest did not arise. In the submission, the assessee has also referred the decision of Hon’ble Jurisdictional Bombay High Court in the case of Apar Industries Ltd. 323 ITR 411 wherein the Hon…

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1 (4) MUMBAI, PRATHISHTHA BHAVAN CHURCHGATE vs. SHUBHENDU AMITABH, DELHI

In the result the appeal of the revenue is dismissed

ITA 3298/MUM/2023[2013-14]Status: DisposedITAT Mumbai30 Jul 2024AY 2013-14

Bench: Shri Amarjit Singh & Shri Sunil Kumar Singh, Juducial Member

For Appellant: Shri Rajiv Khandelwal, CA & Shri Akash KumarFor Respondent: Shri B. Laxmi Kanth, Sr. DR
Section 132(4)Section 139(1)Section 154Section 234BSection 245CSection 245D(4)

…,887 249,996,270 3. I request you to kindly adjust cash seized of Rs. 249,996,270/- against above tax kiability. Thanking you Yours faithfully, (Shubhendu Amitabh) 11. We have also perused decision of Hon’ble Supreme Court in the case of CIT vs Pranoy Roy 309 ITR 231 (SC) wherein held that since tax due has already been paid which was not less than tax payable on returned income which was accepted, question of levy of interest did not arise. In the submission, the assessee has also referred the decision of Hon’ble Jurisdictional Bombay High Court in the case of Apar Industries Ltd. 323 ITR 411 wherein the Hon…

M/S SANTHIMADOM AYURNIKETHAN HEALTH RESORT & RESEARCH INSTITUTE TRUST,KOCHI vs. ACIT CENTRAL CIRCLE -2, KOCHI

In the result, the assessee’s appeals are allowed for statistical purposes

ITA 919/COCH/2022[2009-10]Status: DisposedITAT Cochin02 May 2024AY 2009-10

Bench: Shri Sanjay Arora & Ms. Kavitha Rajagopal

For Appellant: Shri Mathew Joseph, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 153ASection 153CSection 234A

…ble. Two, we may clarify that the nature of levy as mandatory, as well as compensatory, and of the default being a continuing one, is not in dispute, so that demand, where paid, would automatically close the interest, even as found in CIT v. Pranoy Roy [2009] 309 ITR 231 (SC). The compensatory aspect, which also prevailed with the Apex Court in Modi Industries Ltd. (supra), stands met by the extant law providing for interest up to the date of grant of interest; a statutory confirmation of the interest being compensatory. The dispute concerns only the aspect of ‘date of regular assessment’ in the given facts and c…

M/S SANTHIMADOM AYURNIKETHAN HEALTH RESORT & RESEARCH INSTITUTE TRUST,KOCHI vs. ACIT CENTRAL CIRCLE 2, KOCHI

In the result, the assessee’s appeals are allowed for statistical purposes

ITA 918/COCH/2022[2008-09]Status: DisposedITAT Cochin02 May 2024AY 2008-09

Bench: Shri Sanjay Arora & Ms. Kavitha Rajagopal

For Appellant: Shri Mathew Joseph, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 153ASection 153CSection 234A

…ble. Two, we may clarify that the nature of levy as mandatory, as well as compensatory, and of the default being a continuing one, is not in dispute, so that demand, where paid, would automatically close the interest, even as found in CIT v. Pranoy Roy [2009] 309 ITR 231 (SC). The compensatory aspect, which also prevailed with the Apex Court in Modi Industries Ltd. (supra), stands met by the extant law providing for interest up to the date of grant of interest; a statutory confirmation of the interest being compensatory. The dispute concerns only the aspect of ‘date of regular assessment’ in the given facts and c…

M/S SANTHIMADOM AYURNIKETHAN HEALTH RESORT & RESEARCH INSTITUTE TRUST,KOCHI vs. ACIT CENTRAL CIRCLE -2, KOCHI

In the result, the assessee’s appeals are allowed for statistical purposes

ITA 917/COCH/2022[2007-08]Status: DisposedITAT Cochin02 May 2024AY 2007-08

Bench: Shri Sanjay Arora & Ms. Kavitha Rajagopal

For Appellant: Shri Mathew Joseph, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 153ASection 153CSection 234A

…ble. Two, we may clarify that the nature of levy as mandatory, as well as compensatory, and of the default being a continuing one, is not in dispute, so that demand, where paid, would automatically close the interest, even as found in CIT v. Pranoy Roy [2009] 309 ITR 231 (SC). The compensatory aspect, which also prevailed with the Apex Court in Modi Industries Ltd. (supra), stands met by the extant law providing for interest up to the date of grant of interest; a statutory confirmation of the interest being compensatory. The dispute concerns only the aspect of ‘date of regular assessment’ in the given facts and c…

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