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“Section 220(2)”

Section References (mined)Section 220Section 220(2)801 judgments

The decision most relied on for Section 220(2) is Fatehraj Singhvi v. UOI (73 Taxmann.com 252), cited in 1,778 judgments on BharatTax.

Leading authorities on Section 220(2)

Fatehraj Singhvi v. UOI
73 Taxmann.com 252 · 2016 · High Court
1,778
citing judgments

Late fees under section 234E are not applicable for periods prior to June 1, 2015, as the amendment to section 200A inserting clause (c) was effective from that date.

Kourani v. Union OF India
83 Taxmann.com 137 · 2017 · High Court
1,708
citing judgments

The fee under Section 234E for late filing of TDS/TCS statements cannot be levied retrospectively by processing an intimation under Section 200A for defaults occurring before the amendment allowing such processing.

Fateh Raj Singhvi & Ors. v. UOI
289 CTR 602 · 2016 · High Court
844
citing judgments

A fee under Section 234E cannot be levied or adjusted in an intimation under Section 200A for TDS statements pertaining to periods prior to June 1, 2015, as the enabling amendment to Section 200A(1)(c) came into effect only from that date.

Rashmikant Kundalia v. Union of India
54 Taxmann.com 200 · 2015 · High Court
702
citing judgments

Section 234E, levying late fees for delayed filing of TDS statements under section 200(3), is constitutionally valid and constitutes a compensatory fee, not a punitive penalty. Before treating any person as an assessee-in-default, an opportunity of being heard must be provided.

Olari Little Flower Kuries (P.) Ltd. v. UOI
440 ITR 26 · 2022 · High Court
614
citing judgments

The fee under Section 234E of the Income-tax Act cannot be levied for defaults in filing TDS statements committed prior to June 1, 2015, as the provision for its levy became effective only from that date.

Gajanan Constructions v. DCIT
74 Taxmann.com 6 · 2016 · ITAT
465
citing judgments

Late fees under section 234E can only be levied prospectively from June 1, 2015. Levying late fees for periods prior to this date is not permissible.

Dundlod Shikshan Sansthan v. Union of India
63 Taxmann.com 243 · 2015 · High Court
397
citing judgments

The imposition of fees for late filing of TDS/TCS returns prior to the Finance Act, 2015 amendments was not illegal, and the Rajasthan High Court found no justification to interfere with such compensatory fees.

Jiji Varghese v. ITO(TDS) & Ors.
443 ITR 267 · 2022 · High Court
220
citing judgments

Section 234E fee cannot be imposed for periods prior to June 1, 2015. This applies even when the processing of the return under Section 200A(c) occurred before that date.

Judgments citing Section 220(2)

Estate Officer, Principal Chief Conservator of Forest, Nagpur vs. Deputy Commissioner of Income Tax, TDS-CPC, Ghaziabad

In the result, appeal filed by the assessee being ITA no

ITA 140/NAG/2023[2019-20 (Q-1)]Status: DisposedITAT Nagpur16 May 2024

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: NoneFor Respondent: Shri Abhay Y. Marathe
Section 250Section 253(1)Section 253(5)

read with Section 234E of the Act. 4. The learned AO has erred in raising demand on account of interest on payments under section 220(2) of Rs. 20,250/-. 5. The Appellant prays leave of the Hon'ble Tribunal to add, amend, alter any of the Grounds of Appeal

Estate Officer, Principal Chief Conservator of Forest, Nagpur vs. Deputy Commissioner of Income Tax, TDS-CPC, Ghaziabad

In the result, appeal filed by the assessee being ITA no

ITA 138/NAG/2023[2018-19 (Q-3)]Status: DisposedITAT Nagpur16 May 2024

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: NoneFor Respondent: Shri Abhay Y. Marathe
Section 250Section 253(1)Section 253(5)

read with Section 234E of the Act. 4. The learned AO has erred in raising demand on account of interest on payments under section 220(2) of Rs. 20,250/-. 5. The Appellant prays leave of the Hon'ble Tribunal to add, amend, alter any of the Grounds of Appeal

Estate Officer, Principal Chief Conservator of Forest, Ghaziabad vs. Deputy Commissione of Incomde Ef, Gaziabadqqq

In the result, appeal filed by the assessee being ITA no

ITA 137/NAG/2023[2018-19 (Q-2)]Status: DisposedITAT Nagpur16 May 2024

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: NoneFor Respondent: Shri Abhay Y. Marathe
Section 250Section 253(1)Section 253(5)

read with Section 234E of the Act. 4. The learned AO has erred in raising demand on account of interest on payments under section 220(2) of Rs. 20,250/-. 5. The Appellant prays leave of the Hon'ble Tribunal to add, amend, alter any of the Grounds of Appeal

Estate Officer, Principal Chief Conservator of Forest, Nagpur vs. Deputy Commissioner of Income Tax, TDS CPC, Ghaziabad

In the result, appeal filed by the assessee being ITA no

ITA 136/NAG/2023[2018-19 (Q-1)]Status: DisposedITAT Nagpur16 May 2024

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: NoneFor Respondent: Shri Abhay Y. Marathe
Section 250Section 253(1)Section 253(5)

read with Section 234E of the Act. 4. The learned AO has erred in raising demand on account of interest on payments under section 220(2) of Rs. 20,250/-. 5. The Appellant prays leave of the Hon'ble Tribunal to add, amend, alter any of the Grounds of Appeal

Estate Officer, Principal Chief Conservator of Forest, Nagpur vs. Deputy Commissioner of Income Tax, TDS CPC, Ghaziabad

In the result, appeal filed by the assessee being ITA no

ITA 135/NAG/2023[2016-17]Status: DisposedITAT Nagpur16 May 2024AY 2016-17

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: NoneFor Respondent: Shri Abhay Y. Marathe
Section 250Section 253(1)Section 253(5)

read with Section 234E of the Act. 4. The learned AO has erred in raising demand on account of interest on payments under section 220(2) of Rs. 20,250/-. 5. The Appellant prays leave of the Hon'ble Tribunal to add, amend, alter any of the Grounds of Appeal

Estate Officer, Principal Chief Conservator of Forest, Nagpur vs. Deputy Commissioner of Income Tax. TDS-CPC, Ghaziabad

In the result, appeal filed by the assessee being ITA no

ITA 134/NAG/2023[2015-16]Status: DisposedITAT Nagpur16 May 2024AY 2015-16

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: NoneFor Respondent: Shri Abhay Y. Marathe
Section 250Section 253(1)Section 253(5)

read with Section 234E of the Act. 4. The learned AO has erred in raising demand on account of interest on payments under section 220(2) of Rs. 20,250/-. 5. The Appellant prays leave of the Hon'ble Tribunal to add, amend, alter any of the Grounds of Appeal

DCIT Circle -3(4), Mumbai vs. Idbi Bank Ltd, Mumbai

In the result, appeal filed by the learned AO in ITA number

ITA 3573/MUM/2023[2004-05]Status: DisposedITAT Mumbai08 May 2024AY 2004-05

Bench: Shri Prashant Maharishi, Am & Shri Raj Kumar Chauhan, Jm Idbi Bank Ltd. Dcit Circle 3(4) 7Th Floor, R.No. 559, 5Th Floor, Idbi Tower Wtc Complex Vs. Aaykar Bhavan, M.K. Road, Cuffe Parade, Mumbai-400 020 Mm 400005 (Appellant) (Respondent) Pan No. Aabci8842G

For Appellant: Shri C Naresh, ARFor Respondent: Ms Madhu Malati Ghosh, CIT
Section 143Section 244ASection 244A(1)Section 254

where Revenue has to pay interest on refund, but is equally applied when an assessee is in default and interest is payable under Section 220(2) of the Act. Interest payable under Section 234B and 234C become part of the demand notice issued under Section ... this amount, i.e., the tax payable plus interest payable under Sections 234B and 234C that interest under Section 220(2) is calculated from the date mentioned in the notice of demand till the date of actual payment. Under Explanation to Section 140A(1), it is stipulated where the amount paid

Vidya Sunil Mane, Kolhapur vs. Income Tax Officer TDS, Kolhapur

In the result, appeal of the assessee is Partly Allowed

ITA 131/PUN/2024[AY2014-2015 TDS Q4FY2013-2014]Status: DisposedITAT Pune26 Mar 2024

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.128, 129, 130 & 131/Pun/2024 िनधा"रणवष" / Assessment Years : 2013-14 & 2014-15 Vidya Sunil Mane, The Income Tax Officer, F1 Midc, Gokulshirgaon V Tds, Kolhapur. Kolhpur, Kolhapur – 416234. S Pan: Acbpm1640F Appellant/ Assessee Respondent /Revenue Assessee By Shri Mayuresh Doshi – Ar Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 19/03/2024 Date Of Pronouncement 26/03/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Four Appeals Filed By The Assessee Are Against The Common Order Of Ld.Commissioner Of Income Tax(Appeals) [Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 21.11.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.128/Pun/2024 For A.Y.2013-14, As A Lead Case. The Assessee For A.Y.2013-14 Has Raised The Following Grounds Of Appeal :

Section 200ASection 220(2)Section 234ESection 250

Ground No.1 and 2 of the assessee are allowed. 2.1 The ld.AR has not argued Ground No.3 which is related to interest under section 220(2) of the Act. According, Ground No.3 is dismissed. 2.2 The Ground No.4 is general in nature and does not need adjudication, hence dismissed

Vidya Sunil Mane, Kolhapur vs. Income Tax Officer TDS, Kolhapur

In the result, appeal of the assessee is Partly Allowed

ITA 130/PUN/2024[AY2014-2015 TDS Q3FY2013-2014]Status: DisposedITAT Pune26 Mar 2024

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.128, 129, 130 & 131/Pun/2024 िनधा"रणवष" / Assessment Years : 2013-14 & 2014-15 Vidya Sunil Mane, The Income Tax Officer, F1 Midc, Gokulshirgaon V Tds, Kolhapur. Kolhpur, Kolhapur – 416234. S Pan: Acbpm1640F Appellant/ Assessee Respondent /Revenue Assessee By Shri Mayuresh Doshi – Ar Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 19/03/2024 Date Of Pronouncement 26/03/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Four Appeals Filed By The Assessee Are Against The Common Order Of Ld.Commissioner Of Income Tax(Appeals) [Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 21.11.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.128/Pun/2024 For A.Y.2013-14, As A Lead Case. The Assessee For A.Y.2013-14 Has Raised The Following Grounds Of Appeal :

Section 200ASection 220(2)Section 234ESection 250

Ground No.1 and 2 of the assessee are allowed. 2.1 The ld.AR has not argued Ground No.3 which is related to interest under section 220(2) of the Act. According, Ground No.3 is dismissed. 2.2 The Ground No.4 is general in nature and does not need adjudication, hence dismissed

Vidya Sunil Mane, Kolhapur vs. Income Tax Officer TDS, Kolhapur

In the result, appeal of the assessee is Partly Allowed

ITA 129/PUN/2024[AY2014-2015 TDS Q2FY2013-2014]Status: DisposedITAT Pune26 Mar 2024

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.128, 129, 130 & 131/Pun/2024 िनधा"रणवष" / Assessment Years : 2013-14 & 2014-15 Vidya Sunil Mane, The Income Tax Officer, F1 Midc, Gokulshirgaon V Tds, Kolhapur. Kolhpur, Kolhapur – 416234. S Pan: Acbpm1640F Appellant/ Assessee Respondent /Revenue Assessee By Shri Mayuresh Doshi – Ar Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 19/03/2024 Date Of Pronouncement 26/03/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Four Appeals Filed By The Assessee Are Against The Common Order Of Ld.Commissioner Of Income Tax(Appeals) [Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 21.11.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.128/Pun/2024 For A.Y.2013-14, As A Lead Case. The Assessee For A.Y.2013-14 Has Raised The Following Grounds Of Appeal :

Section 200ASection 220(2)Section 234ESection 250

Ground No.1 and 2 of the assessee are allowed. 2.1 The ld.AR has not argued Ground No.3 which is related to interest under section 220(2) of the Act. According, Ground No.3 is dismissed. 2.2 The Ground No.4 is general in nature and does not need adjudication, hence dismissed

Vidya Sunil Mane, Kolhapur vs. Income Tax Officer TDS Kolhapur, Kolhapur

In the result, appeal of the assessee is Partly Allowed

ITA 128/PUN/2024[2013-2014 TDS Q4 FY2012-2013]Status: DisposedITAT Pune26 Mar 2024

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.128, 129, 130 & 131/Pun/2024 िनधा"रणवष" / Assessment Years : 2013-14 & 2014-15 Vidya Sunil Mane, The Income Tax Officer, F1 Midc, Gokulshirgaon V Tds, Kolhapur. Kolhpur, Kolhapur – 416234. S Pan: Acbpm1640F Appellant/ Assessee Respondent /Revenue Assessee By Shri Mayuresh Doshi – Ar Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 19/03/2024 Date Of Pronouncement 26/03/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Four Appeals Filed By The Assessee Are Against The Common Order Of Ld.Commissioner Of Income Tax(Appeals) [Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 21.11.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.128/Pun/2024 For A.Y.2013-14, As A Lead Case. The Assessee For A.Y.2013-14 Has Raised The Following Grounds Of Appeal :

Section 200ASection 220(2)Section 234ESection 250

Ground No.1 and 2 of the assessee are allowed. 2.1 The ld.AR has not argued Ground No.3 which is related to interest under section 220(2) of the Act. According, Ground No.3 is dismissed. 2.2 The Ground No.4 is general in nature and does not need adjudication, hence dismissed

Pooja Crafted Homes Private Limited, Hyderabad vs. ACIT, Central Circle-1(2), Hyderabad

In the result, appeal filed by the assessee is dismissed

ITA 61/HYD/2024[2018-19]Status: DisposedITAT Hyderabad25 Mar 2024AY 2018-19

Bench: Shri R.K. Panda, Vice- & Shri K. Narasimha Charyआ.अपी.सं /Ita No. 61/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2018-19) Pooja Crafted Homes (P) Vs. Asstt. C. I. T. Ltd, Hyderabad Central Circle 1(2) Pan:Aadcp2869A Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate S K Gupta, राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr सुनवाई की तारीख/Date Of Hearing: 04/03/2024 घोषणा की तारीख/Pronouncement: 25/03/2024 आदेश/Order

For Appellant: Advocate S K GuptaFor Respondent: : Shri Shakeer Ahmed, DR
Section 143(2)Section 194CSection 37Section 40

ITA 61 of 2024 Pooja Crafted Homes P Ltd आयकर अपील"य अ"धकरण, हैदराबाद पीठ IN THE INCOME TAX

M/S Ceecon Readymix Concrete Pvt Ltd, Thrissur vs. ITO TDS Range, Thrissur

In the result, the assessee’s appeals are allowed on the afore-said terms

ITA 1014/COCH/2022[2015-16]Status: DisposedITAT Cochin29 Feb 2024AY 2015-16

Bench: Shri Sanjay Arora & Shri Manomohan Das

For Appellant: Ms. Divya Ravindran, AdvocateFor Respondent: Smt. J M Jamuna Devi, Sr. DR
Section 154Section 156Section 192Section 194JSection 200(3)Section 200ASection 220(2)Section 234E

IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN Before Shri Sanjay Arora, Accountant Member and Shri Manomohan Das, Judicial

M/S Ceecon Readymix Concrete Pvt Ltd, Thrissur vs. ITO TDS Range, Thrissur

In the result, the assessee’s appeals are allowed on the afore-said terms

ITA 1013/COCH/2022[2014-15]Status: DisposedITAT Cochin29 Feb 2024AY 2014-15

Bench: Shri Sanjay Arora & Shri Manomohan Das

For Appellant: Ms. Divya Ravindran, AdvocateFor Respondent: Smt. J M Jamuna Devi, Sr. DR
Section 154Section 156Section 192Section 194JSection 200(3)Section 200ASection 220(2)Section 234E

IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN Before Shri Sanjay Arora, Accountant Member and Shri Manomohan Das, Judicial

M/S. Calcutta Springs Ltd., Kolkata vs. D.C.I.T., CC- 1(2), Kolkata

In the result, the appeal of the assessee is allowed

ITA 768/KOL/2022[2014-2015]Status: DisposedITAT Kolkata22 Feb 2024AY 2014-2015

Bench: Dr. Manish Borad & Shri Sonjoy Sarma]

Section 115JSection 143(3)Section 14ASection 153ASection 154Section 220(2)

IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA BENCH ‘C’, KOLKATA [Before Dr. Manish Borad, Accountant Member & Shri Sonjoy Sarma, Judicial

Pudhari Publications Private Limited, Kolhapur vs. Income Tax Officer, TDS, Kolhapur

In the result, both appeals of the assessee in ITA

ITA 12/PUN/2024[2021-22]Status: HeardITAT Pune20 Feb 2024AY 2021-22

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.10 To 12/Pun/2024 िनधा"रण वष" / Assessment Years: 2019-20, 2020-21 & 2021-22 Pudhari Publications Private Ltd., The Ito, Tds, 2318, C Ward, Pudhari Bhavan, V Kolhapur – 416003. Bhausingji Road, S Kolhapur – 416002. Pan: Aadcp2453Q Appellant/ Assessee Respondent /Revenue Assessee By Shri S.N.Puranik – Ar Revenue By Shri Ajay Kumar Keshari – Dr Date Of Hearing 19/02/2024 Date Of Pronouncement 20/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 10.11.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.10/Pun/2024 For A.Y.2019-20, As A Lead Case. The Assessee For A.Y.2019-20 Has Raised The Following Grounds Of Appeal :

Section 154Section 192Section 201(1)Section 220(2)Section 250Section 250(4)Section 250(6)Section 251Section 251(1)(a)

correct in confirming Order passed under section 154 by AO at CPC, in respect of Interest under section 220(2) amounting to Rs. 1,28,858 for delayed payment of Interest on TDS on without appreciating the fact that Interest on TDS on Salary itself is not tenable

Pudhari Publications Private Ltd, Kolhapur vs. Income Tax Officer, TDS, Kolhapur

In the result, both appeals of the assessee in ITA

ITA 11/PUN/2024[2020-21]Status: HeardITAT Pune20 Feb 2024AY 2020-21

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.10 To 12/Pun/2024 िनधा"रण वष" / Assessment Years: 2019-20, 2020-21 & 2021-22 Pudhari Publications Private Ltd., The Ito, Tds, 2318, C Ward, Pudhari Bhavan, V Kolhapur – 416003. Bhausingji Road, S Kolhapur – 416002. Pan: Aadcp2453Q Appellant/ Assessee Respondent /Revenue Assessee By Shri S.N.Puranik – Ar Revenue By Shri Ajay Kumar Keshari – Dr Date Of Hearing 19/02/2024 Date Of Pronouncement 20/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 10.11.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.10/Pun/2024 For A.Y.2019-20, As A Lead Case. The Assessee For A.Y.2019-20 Has Raised The Following Grounds Of Appeal :

Section 154Section 192Section 201(1)Section 220(2)Section 250Section 250(4)Section 250(6)Section 251Section 251(1)(a)

correct in confirming Order passed under section 154 by AO at CPC, in respect of Interest under section 220(2) amounting to Rs. 1,28,858 for delayed payment of Interest on TDS on without appreciating the fact that Interest on TDS on Salary itself is not tenable

Pudhari Publications Private Limited, Kolhapur vs. Income Tax Officer, TDS, Kolhapur

In the result, both appeals of the assessee in ITA

ITA 10/PUN/2024[2019-20]Status: HeardITAT Pune20 Feb 2024AY 2019-20

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.10 To 12/Pun/2024 िनधा"रण वष" / Assessment Years: 2019-20, 2020-21 & 2021-22 Pudhari Publications Private Ltd., The Ito, Tds, 2318, C Ward, Pudhari Bhavan, V Kolhapur – 416003. Bhausingji Road, S Kolhapur – 416002. Pan: Aadcp2453Q Appellant/ Assessee Respondent /Revenue Assessee By Shri S.N.Puranik – Ar Revenue By Shri Ajay Kumar Keshari – Dr Date Of Hearing 19/02/2024 Date Of Pronouncement 20/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 10.11.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.10/Pun/2024 For A.Y.2019-20, As A Lead Case. The Assessee For A.Y.2019-20 Has Raised The Following Grounds Of Appeal :

Section 154Section 192Section 201(1)Section 220(2)Section 250Section 250(4)Section 250(6)Section 251Section 251(1)(a)

correct in confirming Order passed under section 154 by AO at CPC, in respect of Interest under section 220(2) amounting to Rs. 1,28,858 for delayed payment of Interest on TDS on without appreciating the fact that Interest on TDS on Salary itself is not tenable

Techmobia Digital Solutions Pvt. Ltd., New Delhi vs. DCIT, Circle-76(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 1853/DEL/2022[2013-14]Status: DisposedITAT Delhi18 Jan 2024AY 2013-14

Bench: Dr. B. R. R. Kumar, Shri Yogesh Kumar Us

For Appellant: Sh. Shailesh Gupta, CAFor Respondent: Sh. Amit Katoch, Sr. DR
Section 194ISection 200(3)Section 201Section 23Section 234ESection 246

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘H’, NEW DELHI Before Dr. B. R. R. Kumar, Accountant Member, Shri

Sony India Private Limited, New Delhi vs. DCIT CPC, Bangalore

In the result, appeal is allowed

ITA 1667/DEL/2020[2017-18]Status: DisposedITAT Delhi04 Jan 2024AY 2017-18

Bench: Shri G.S. Pannu, Vice- & Shri Saktijit Dey, Vice-Assessment Year: 2017-18

Section 115WSection 143(1)Section 220(2)Section 282

assessee has raised multiple grounds, however, the core issue arising for consideration is relating to chargeability of AY: 2017-18 interest under section 220(2) of the Income-tax Act, 1961 (in short ‘the Act’). 3. Briefly the facts relating to the issue in dispute are, the assessee ... Fringe Benefit Tax (FBT) demand under section 115WE of the Act for the assessment year 2009-10 created on 04.01.2011 and interest under section 220(2) thereon amounting to Rs.91,84,500/- i.e. up to the date of processing of the return on 26.05.2019. Aggrieved with the adjustment of refund