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“interest under section 201(1A)”

TDS / TCSSection 201(1A)Section 201(1A)369 judgments

The decision most relied on for interest under section 201(1A) is Hindustan Coca Cola Beverage Pvt. Ltd. v. CIT (293 ITR 226), cited in 576 judgments on BharatTax.

Leading authorities on interest under section 201(1A)

Hindustan Coca Cola Beverage Pvt. Ltd. v. CIT
293 ITR 226 · 2007 · Supreme Court
576
citing judgments

The deductor cannot be treated as an assessee-in-default under Section 201(1) if the deductee has already paid the tax or offered the impugned receipts in their return of income. However, interest under Section 201(1A) for delayed deposit of tax can still be levied up to the date of filing of the return of income by the deductee.

Prakash Cotton Mills Pvt. Ltd. v. CIT
201 ITR 684 · 1993 · Supreme Court
133
citing judgments

Compensatory interest or damages paid for a breach of contract, arising in the normal course of business, are allowable as a deduction under section 37(1) as wholly and exclusively incurred for business purposes. This principle extends to indirect taxes paid in the course of business, which are admissible as business expenditure.

Bharat Commerce Industries Ltd. v. CIT
230 ITR 733 · 1998 · Supreme Court
130
citing judgments

The Supreme Court holds that interest paid under Section 201(1A) of the Income-tax Act, for failure to deduct tax at source, is not an allowable business expenditure under Section 37(1) of the Act.

Lachmandas Mathura v. CIT
254 ITR 799 · 2002 · Supreme Court
119
citing judgments

Interest paid on delayed payment of statutory dues, such as sales tax, service tax, TDS, and GST, is compensatory in nature rather than penal. Consequently, such interest is an allowable deduction in computing business profits.

American Express International Banking Corporation v. CIT
258 ITR 601 · 2002 · High Court
90
citing judgments

Interest paid by banks is allowable as a deduction in computing total income. The decision distinguished the Supreme Court's ruling in Vijaya Bank regarding the deductibility of such interest.

CIT v. Chennai Properties & Investment Ltd.
239 ITR 435 · 1999 · High Court
77
citing judgments

Interest paid under section 201(1A) for delay in remitting tax deducted at source is not an allowable business expenditure and cannot be regarded as a compensatory payment. This interest takes its character from the nature of the tax levy, being a direct tax itself.

CIT v. Oriental Insurance Co. Ltd.
125 Taxmann 1094 · 2002 · High Court
77
citing judgments

Interest levied under Section 201(1A) for delayed remittance of Tax Deducted at Source (TDS) is compensatory in nature, not penal. It is a distinct provision for delayed remittance, similar to interest paid by Revenue on refunds.

Bank Ltd. (supra), Saraswat Co-op. Bank Ltd. v. ITO (TDS)
54 Taxmann.com 297 · 2015 · Reported
76
citing judgments

A multi-state cooperative bank is obligated to deduct tax at source on interest paid on fixed deposits placed by cooperative societies, as Section 194A(3)(viia) of the Income Tax Act, 1961, rather than Section 194A(3)(v), applies to cooperative banks in this context.

Judgments citing interest under section 201(1A)

ITO(TDS), Ajmer vs. Divisionl Forest Officer, Ajmer

In the result, the appeal of the revenue in ITA no

ITA 360/JPR/2023[2018-19]Status: DisposedITAT Jaipur08 Nov 2023AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. Nos. 358 to 360/JP/2023 fu/kZkj.k o"kZ@Assessment Years : 2016-17 to 2018-19 Income Tax Officer (TDS), Ajmer cuke Vs. Divisional Forest Officer Ajmer LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No. JDHD 02557 C vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. Sunil Porwal (CA) jktLo dh vksj ls@ Revenue by : Sh. Anup Singh (Addl. CIT) lquokbZ dh rkjh[k@ Date of Hearing :

For Appellant: Sh. Sunil Porwal (CA)For Respondent: Sh. Anup Singh (Addl. CIT)
Section 10Section 10(20)Section 10(46)Section 11Section 133Section 194CSection 201Section 201(1)Section 80P

further noted the contents of the Circular dated 29.01.1997 issued by CBDT and held that the deductor assessee was liable to pay interest under section 201(1A) of the Act till the date of payment of taxes by the deductee assessee, observing as under:- “10 Be that

Income Tax Officer (TDS), Ajmer vs. Divisionl Forest Officer, Ajmer

In the result, the appeal of the revenue in ITA no

ITA 359/JPR/2023[2017-18]Status: DisposedITAT Jaipur08 Nov 2023AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. Nos. 358 to 360/JP/2023 fu/kZkj.k o"kZ@Assessment Years : 2016-17 to 2018-19 Income Tax Officer (TDS), Ajmer cuke Vs. Divisional Forest Officer Ajmer LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No. JDHD 02557 C vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. Sunil Porwal (CA) jktLo dh vksj ls@ Revenue by : Sh. Anup Singh (Addl. CIT) lquokbZ dh rkjh[k@ Date of Hearing :

For Appellant: Sh. Sunil Porwal (CA)For Respondent: Sh. Anup Singh (Addl. CIT)
Section 10Section 10(20)Section 10(46)Section 11Section 133Section 194CSection 201Section 201(1)Section 80P

further noted the contents of the Circular dated 29.01.1997 issued by CBDT and held that the deductor assessee was liable to pay interest under section 201(1A) of the Act till the date of payment of taxes by the deductee assessee, observing as under:- “10 Be that

Income Tax Officer (TDS), Ajmer vs. Divisionl Forest Officer, Ajmer

In the result, the appeal of the revenue in ITA no

ITA 358/JPR/2023[2016-17]Status: DisposedITAT Jaipur08 Nov 2023AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. Nos. 358 to 360/JP/2023 fu/kZkj.k o"kZ@Assessment Years : 2016-17 to 2018-19 Income Tax Officer (TDS), Ajmer cuke Vs. Divisional Forest Officer Ajmer LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No. JDHD 02557 C vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. Sunil Porwal (CA) jktLo dh vksj ls@ Revenue by : Sh. Anup Singh (Addl. CIT) lquokbZ dh rkjh[k@ Date of Hearing :

For Appellant: Sh. Sunil Porwal (CA)For Respondent: Sh. Anup Singh (Addl. CIT)
Section 10Section 10(20)Section 10(46)Section 11Section 133Section 194CSection 201Section 201(1)Section 80P

further noted the contents of the Circular dated 29.01.1997 issued by CBDT and held that the deductor assessee was liable to pay interest under section 201(1A) of the Act till the date of payment of taxes by the deductee assessee, observing as under:- “10 Be that

Zee Entertainment Enterprises Limited, Mumbai vs. JCIT(TDS)(OSD)-2(3), Mumbai

In the result, we confirm the appellate order passed by the CIT (A) for assessment year 2013 – 14 and dismiss all the grounds raised by the assessee in this appeal

ITA 2097/MUM/2023[2018-19]Status: DisposedITAT Mumbai31 Oct 2023AY 2018-19

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Madhur Agarwal Advocate and Shri Jay Bhansali ARFor Respondent: Shri ram Krishna Kedia Sr DR
Section 133ASection 201Section 40

parties have been ascertained. Further he found that subsequently the assessee has deducted tax at source and therefore only the interest under section 201 (1A) of the act is payable. Accordingly he computed the interest under section 201 (1A) for the period from the date provision is made ... deduction at source on such provisions and accordingly interest is worked out on invoice value of ₹ 160,550,000 and consequent interest under section 201 (1A) of ₹ 1,573,084/–. x. The order under section 201 (1A of the act was passed on 23/10/2020. 04. Assessee approached the learned

Zee Entertainment Enterprises Limited, Mumbai vs. Joint Commissioner of Income Tax, OSD(TDS)-2(3), Mumbai(Present in Charge JCIT CC-2(4), Mumbai

In the result, we confirm the appellate order passed by the CIT (A) for assessment year 2013 – 14 and dismiss all the grounds raised by the assessee in this appeal

ITA 2096/MUM/2023[2019-20]Status: DisposedITAT Mumbai31 Oct 2023AY 2019-20

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Madhur Agarwal Advocate and Shri Jay Bhansali ARFor Respondent: Shri ram Krishna Kedia Sr DR
Section 133ASection 201Section 40

parties have been ascertained. Further he found that subsequently the assessee has deducted tax at source and therefore only the interest under section 201 (1A) of the act is payable. Accordingly he computed the interest under section 201 (1A) for the period from the date provision is made ... deduction at source on such provisions and accordingly interest is worked out on invoice value of ₹ 160,550,000 and consequent interest under section 201 (1A) of ₹ 1,573,084/–. x. The order under section 201 (1A of the act was passed on 23/10/2020. 04. Assessee approached the learned

Zee Entertainment Enterprises Limited, Mumbai vs. JCIT(TDS)(OSD)-2(3), Mumbai

In the result, we confirm the appellate order passed by the CIT (A) for assessment year 2013 – 14 and dismiss all the grounds raised by the assessee in this appeal

ITA 2095/MUM/2023[2017-18]Status: DisposedITAT Mumbai31 Oct 2023AY 2017-18

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Madhur Agarwal Advocate and Shri Jay Bhansali ARFor Respondent: Shri ram Krishna Kedia Sr DR
Section 133ASection 201Section 40

parties have been ascertained. Further he found that subsequently the assessee has deducted tax at source and therefore only the interest under section 201 (1A) of the act is payable. Accordingly he computed the interest under section 201 (1A) for the period from the date provision is made ... deduction at source on such provisions and accordingly interest is worked out on invoice value of ₹ 160,550,000 and consequent interest under section 201 (1A) of ₹ 1,573,084/–. x. The order under section 201 (1A of the act was passed on 23/10/2020. 04. Assessee approached the learned

Zee Entertainment Enterprises Limited, Mumbai vs. JCIT(TDS)(OSD)-2(3), Mumbai

In the result, we confirm the appellate order passed by the CIT (A) for assessment year 2013 – 14 and dismiss all the grounds raised by the assessee in this appeal

ITA 2094/MUM/2023[2016-17]Status: DisposedITAT Mumbai31 Oct 2023AY 2016-17

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Madhur Agarwal Advocate and Shri Jay Bhansali ARFor Respondent: Shri ram Krishna Kedia Sr DR
Section 133ASection 201Section 40

parties have been ascertained. Further he found that subsequently the assessee has deducted tax at source and therefore only the interest under section 201 (1A) of the act is payable. Accordingly he computed the interest under section 201 (1A) for the period from the date provision is made ... deduction at source on such provisions and accordingly interest is worked out on invoice value of ₹ 160,550,000 and consequent interest under section 201 (1A) of ₹ 1,573,084/–. x. The order under section 201 (1A of the act was passed on 23/10/2020. 04. Assessee approached the learned

Zee Entertainment Enterprises Limited, Mumbai vs. JCIT(TDS)(OSD)-2(3), Mumbai

In the result, we confirm the appellate order passed by the CIT (A) for assessment year 2013 – 14 and dismiss all the grounds raised by the assessee in this appeal

ITA 2093/MUM/2023[2015-16]Status: DisposedITAT Mumbai31 Oct 2023AY 2015-16

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Madhur Agarwal Advocate and Shri Jay Bhansali ARFor Respondent: Shri ram Krishna Kedia Sr DR
Section 133ASection 201Section 40

parties have been ascertained. Further he found that subsequently the assessee has deducted tax at source and therefore only the interest under section 201 (1A) of the act is payable. Accordingly he computed the interest under section 201 (1A) for the period from the date provision is made ... deduction at source on such provisions and accordingly interest is worked out on invoice value of ₹ 160,550,000 and consequent interest under section 201 (1A) of ₹ 1,573,084/–. x. The order under section 201 (1A of the act was passed on 23/10/2020. 04. Assessee approached the learned

Zee Entertainment Enterprises Limited, Mumbai vs. JCIT(TDS)(OSD)-2(3), Mumbai

In the result, we confirm the appellate order passed by the CIT (A) for assessment year 2013 – 14 and dismiss all the grounds raised by the assessee in this appeal

ITA 2092/MUM/2023[2014-15]Status: DisposedITAT Mumbai31 Oct 2023AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Madhur Agarwal Advocate and Shri Jay Bhansali ARFor Respondent: Shri ram Krishna Kedia Sr DR
Section 133ASection 201Section 40

parties have been ascertained. Further he found that subsequently the assessee has deducted tax at source and therefore only the interest under section 201 (1A) of the act is payable. Accordingly he computed the interest under section 201 (1A) for the period from the date provision is made ... deduction at source on such provisions and accordingly interest is worked out on invoice value of ₹ 160,550,000 and consequent interest under section 201 (1A) of ₹ 1,573,084/–. x. The order under section 201 (1A of the act was passed on 23/10/2020. 04. Assessee approached the learned

Zee Entertainment Enterprises Limited, Mumbai vs. JCIT(TDS)(OSD)-2(3), Mumbai

In the result, we confirm the appellate order passed by the CIT (A) for assessment year 2013 – 14 and dismiss all the grounds raised by the assessee in this appeal

ITA 2091/MUM/2023[2013-14]Status: DisposedITAT Mumbai31 Oct 2023AY 2013-14

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Madhur Agarwal Advocate and Shri Jay Bhansali ARFor Respondent: Shri ram Krishna Kedia Sr DR
Section 133ASection 201Section 40

parties have been ascertained. Further he found that subsequently the assessee has deducted tax at source and therefore only the interest under section 201 (1A) of the act is payable. Accordingly he computed the interest under section 201 (1A) for the period from the date provision is made ... deduction at source on such provisions and accordingly interest is worked out on invoice value of ₹ 160,550,000 and consequent interest under section 201 (1A) of ₹ 1,573,084/–. x. The order under section 201 (1A of the act was passed on 23/10/2020. 04. Assessee approached the learned

Shri Shitalbhai Rasiklal Ravani, Rajkot vs. The ITO(TDS)-2, Rajkot

Accordingly, in our considered view, the present appeal is not maintainable and hence the present appeal is being dismissed as non- maintainable

ITA 21/RJT/2020[2016-17]Status: DisposedITAT Rajkot18 Oct 2023AY 2016-17

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Written SubmissionFor Respondent: Shri Shramdeep Sinha, CIT DR
Section 119(2)(a)Section 194Section 194lSection 201Section 201(1)Section 220

201(1 A) can be considered, which are as under. “2. The class of cases in which the reduction or waiver of interest under section 201(1A)(i) can be considered, are as follows: (i) Where during the course of proceedings for search and seizure under section

Commissioner, Cuttack Municipal Corporation, Cuttack vs. ITO(TDS), Cuttack

In the result, appeal of the assessee is allowed

ITA 83/CTK/2020[2014-15]Status: DisposedITAT Cuttack12 Oct 2023AY 2014-15

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अऩीऱ सं/Ita No.83/Ctk/2020 (ननधाारण वषा / Assessment Year : 2014-2015) Commissioner, Vs Ito (Tds), Cuttack Cuttack Municipal Corporation, Choudhury Bazar, Dist: Cuttack Tan No. :Bbnc 00195 G (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri P.K.Mishra & Sanjeev Swain, Advs राजस्व की ओर से /Revenue By : Shri Charan Dass, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 12/10/2023 घोषणा की तारीख/Date Of Pronouncement : 12/10/2023 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit(A), Cuttack, Dated 31.10.2019, Passed In I.T.Appeal No.0398/2015- 16 For The Assessment Year 2014-2015. 2. The Appeal Of The Assessee Is Delayed By 25 Days For Which The Assessee Has Filed Necessary Application For Condonation Of Delay & The Affidavit. The Reason For Delay Is Mentioned To Be On Account Of Urinary Infection & High Blood Pressure & The Consequential Medical Treatment. The Affidavit Filed By The Assessee Has Not Been Controverted By The Revenue. Consequently, The Delay In Filing The Present Appeal Is Condoned & The Appeal Is Disposed Off On Merits. 3. It Was Submitted By The Ld. Ar That The Issue In The Appeal Was Against Holding The Assessee As An Assessee In Default For Non-Deduction

For Appellant: Shri P.K.Mishra & Sanjeev Swain, AdvsFor Respondent: Shri Charan Dass, Sr. DR
Section 194CSection 201Section 201(1)

time when it had become due, it would not be proper on the part of the revenue to levy any interest under section 201(1A) of the Act, especially when the contractor had paid more amount of tax by way of advance tax than what was payable

Nirmaan Rmbs Trust Series I 2015, Mumbai vs. Dy.Commissioner of Income Tax (TDS)2, Mumbai

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

ITA 3231/MUM/2022[2017-18]Status: DisposedITAT Mumbai28 Sept 2023AY 2017-18

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Percy Pardiwala a/wFor Respondent: Shri Ashok Kumar Ambastha
Section 139Section 194LSection 201Section 201(1)Section 250

erred in not granting the sine die adjournment as requested by the Appellant on 19 July 2022. Ground No 4: Levy of interest under section 201(1A) of the Act. The learned CIT(A) erred on facts and in law in levying interest under section 201(1A ... source under section 194LBC of the Act on the amount of Excess Interest Spread (“EIS”) paid by the assessee, and levying the interest under section 201(1A) of the Act. 4. The brief facts of the case as emanating from the record are: The assessee was established as a Securitisation

Nirmaan Rmbs Trust Series 111 2013, Mumbai vs. Dy Commissioner of Income Tax (TDS) 2(3), Mumbai

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

ITA 2860/MUM/2022[2018-2019]Status: DisposedITAT Mumbai28 Sept 2023AY 2018-2019

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Percy Pardiwala a/wFor Respondent: Shri Ashok Kumar Ambastha
Section 139Section 194LSection 201Section 201(1)Section 250

erred in not granting the sine die adjournment as requested by the Appellant on 19 July 2022. Ground No 4: Levy of interest under section 201(1A) of the Act. The learned CIT(A) erred on facts and in law in levying interest under section 201(1A ... source under section 194LBC of the Act on the amount of Excess Interest Spread (“EIS”) paid by the assessee, and levying the interest under section 201(1A) of the Act. 4. The brief facts of the case as emanating from the record are: The assessee was established as a Securitisation

Nirmaan Rmbs Trust Series III 2013, Mumbai vs. DCIT (TDS) 2(3), Mumbai

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

ITA 2859/MUM/2022[2017-18]Status: DisposedITAT Mumbai28 Sept 2023AY 2017-18

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Percy Pardiwala a/wFor Respondent: Shri Ashok Kumar Ambastha
Section 139Section 194LSection 201Section 201(1)Section 250

erred in not granting the sine die adjournment as requested by the Appellant on 19 July 2022. Ground No 4: Levy of interest under section 201(1A) of the Act. The learned CIT(A) erred on facts and in law in levying interest under section 201(1A ... source under section 194LBC of the Act on the amount of Excess Interest Spread (“EIS”) paid by the assessee, and levying the interest under section 201(1A) of the Act. 4. The brief facts of the case as emanating from the record are: The assessee was established as a Securitisation

Tumkur Minerals Pvt. Ltd, Vasco vs. Joint Commissioner of Income Tax, Margao Range, Margao

In the result, appeal of the assessee is allowed

ITA 401/PAN/2018[2011-12]Status: DisposedITAT Panaji20 Sept 2023AY 2011-12

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing)

For Appellant: Shri P.J. Pardiwalla, AdvFor Respondent: Smt. Ashwini Hosmani, Sr.DR
Section 195Section 40Section 5Section 9(1)(vii)

assessee to be an assessee in default for the financial years 1997-98 to 1999- 2000, and levied tax as well as interest under section 201(1A). The Commissioner (Appeals) rejected the assessee‟s contention that the payments made to the various non-residents for carrying out overhaul repairs were

Maharaja Ganga Mahal, Bikaner vs. ITO, Td, Bikaner

In the result, all the appeals are partly allowed

ITA 85/JODH/2023[2018-19]Status: DisposedITAT Jodhpur18 Sept 2023AY 2018-19

Bench: Shri Saktijit Dey, Vice- & Shri Girish Agrawal

For Appellant: Sh. Shafi Mohd. Chouhan, Adv. &For Respondent: Sh. Rajeev Mohan, JCIT-DR
Section 133ASection 194ASection 194A(3)Section 194CSection 201Section 201(1)

source. Since the assessee has failed to deduct tax at source, the Assessing Officer computed the TDS amount along with interest under section 201(1A) at Rs.6,040/-. In so far as interest paid to AU Financiers (India) Ltd. is concerned, the 201(1) and 201(1A) at Rs.83 ... income has offered it to tax in the return of income filed in the concerned section 201(1) can be raised. However, interest under section 201(1A) has to be charged till the date of payment of tax by the recipient of such income

Maharaja Ganga Mahal, Bikaner vs. ITO, Td, Bikaner

In the result, all the appeals are partly allowed

ITA 84/JODH/2023[2017-18]Status: DisposedITAT Jodhpur18 Sept 2023AY 2017-18

Bench: Shri Saktijit Dey, Vice- & Shri Girish Agrawal

For Appellant: Sh. Shafi Mohd. Chouhan, Adv. &For Respondent: Sh. Rajeev Mohan, JCIT-DR
Section 133ASection 194ASection 194A(3)Section 194CSection 201Section 201(1)

source. Since the assessee has failed to deduct tax at source, the Assessing Officer computed the TDS amount along with interest under section 201(1A) at Rs.6,040/-. In so far as interest paid to AU Financiers (India) Ltd. is concerned, the 201(1) and 201(1A) at Rs.83 ... income has offered it to tax in the return of income filed in the concerned section 201(1) can be raised. However, interest under section 201(1A) has to be charged till the date of payment of tax by the recipient of such income

Maharaja Ganga Mahal, Bikaner vs. ITO, Td, Bikaner

In the result, all the appeals are partly allowed

ITA 83/JODH/2023[2016-17]Status: DisposedITAT Jodhpur18 Sept 2023AY 2016-17

Bench: Shri Saktijit Dey, Vice- & Shri Girish Agrawal

For Appellant: Sh. Shafi Mohd. Chouhan, Adv. &For Respondent: Sh. Rajeev Mohan, JCIT-DR
Section 133ASection 194ASection 194A(3)Section 194CSection 201Section 201(1)

source. Since the assessee has failed to deduct tax at source, the Assessing Officer computed the TDS amount along with interest under section 201(1A) at Rs.6,040/-. In so far as interest paid to AU Financiers (India) Ltd. is concerned, the 201(1) and 201(1A) at Rs.83 ... income has offered it to tax in the return of income filed in the concerned section 201(1) can be raised. However, interest under section 201(1A) has to be charged till the date of payment of tax by the recipient of such income

Pinky Sachdev, Raipur vs. Income Tax Officer (TDS), Raipur

In the result, the appeal of assessee is partly allowed for statistical purposes

ITA 52/RPR/2023[2015-16]Status: DisposedITAT Raipur14 Sept 2023AY 2015-16

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं./Ita No.52/Rpr/2023 िनधा"रण वष" /Assessment Year: 2015-16 V. Pinky Sachdev, Ito (Tds), ‘Nitya’, Plot No.25, Raipur (C.G.)-492 001 Krishna Sakha Society, Rohini Puram, Raipur-492 001 [Pan: Atsps 8079 E] (अपीलाथ"/Appellant) (""यथ"/Respondent) : अपीलाथ" की ओर से/ Appellant By Shri Nikhilesh Begani, C.A. ""थ" की ओर से /Respondent By : Shri Satya Prakash Sharma, Sr. D.R. सुनवाई क" तार"ख/Date Of Hearing : 07.08.2023 घोषणा क" तार"ख /Date Of Pronouncement : 14.09.2023

For Respondent: Shri Satya Prakash Sharma
Section 194Section 194ISection 201Section 201(1)Section 206ASection 250

purchased by her during the relevant financial year. The assessee was also requested to show-cause as to why not liability of interest under Section 201(1A) of the Act and fee under Section 234E of the Act :: 4 :: should be imposed to her for the related fault. No compliance ... assessee is found to be in default since has failed to make TDS as prescribed under provision 194IA of the Act. Accordingly, interest under Section 201(1A) of the Act of Rs.22,00,014/- was worked out for both the joint purchases and the share of the assessee was worked