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“Section 201(14)”

Section References (mined)Section 201Section 201(14)18 judgments

M/S SPEARSEARCH SOLUTIONS,NEW DELHI vs. INCOME TAX OFFICER, NEW DELHI

Appeal is allowed

ITA 3216/DEL/2025[2014-15]Status: DisposedITAT Delhi25 Sept 2025AY 2014-15

Bench: Shri Satbeer Singh Godara\Nand\Nshri S. Rifaur Rahman\Nita No.3216/Del/2025\N Assessment Year: 2014-15\Nm/S. Spearsearch Solutions,\Nf-4 & 5, Street No. 3, Near\Nnathu Sweets, Laxmi Nagar,\Nvikas Marg,\Nnew Delhi\Npan: Abofs7069J\N(Appellant)\Nvs.\Nincome Tax Officer,\Nward-77(3),\Nnew Delhi\N(Respondent)\Nassessee By\Ndepartment By\Nsh. P.D. Mittal, Ca\Nsh. Om Prakash, Sr. Dr\Ndate Of Hearing\Ndate Of Pronouncement\N25.09.2025\N25.09.2025\Norder\Nper Satbeer Singh Godara, Jm\Nthis Assessee'S Appeal For Assessment Year 2014-15, Arises\Nagainst The Commissioner Of Income Tax (Appeals)/Addl./Jcit(A)-\N1, Mumbai'S Din & Order No.\Nitba/Apl/S/250/2024-\N25/1074646000(1), Dated 18.03.2025 Involving Proceedings Under\Nsection 201 Of The Income-Tax Act, 1961 (Hereinafter Referred To As\N'The Act').\N2.\Nheard Both The Parties. Case File Perused.\Ncoming To The Assessee'S Sole Substantive Ground That Both\Nthe Learned Lower Authorities Herein Have Erred In Law & On Facts\Nin Treating It As The Assessee In Default In Section 201(1)\Nproceedings We Note At The Outset That The Lower Appellate\Ndiscussion To This Effect Reads As Under:\N“Submission- The Submission Of The Assessee Is Reproduced As Under:\Nsub: Response To Notice U/S 250 Vide Din: Itba/Nfac/F/Apl\N1/2022-23/1050402744(1) Dated 04.03.2023 In Case Of M/S\Nspearsearch Solutions (Pan: Abofs7069] & Tan: Dels389078), F4\N& 5. 1 Fluor.

Section 194Section 194CSection 201Section 201(1)Section 250Section 44ASection 9

Hindustan Coca Cola Beverages P. Ltd. Vs\nCIT (supra) and Instruction of CBDT as per its Circular\nNo.275/201/95-IT(B) dated 29.1.1997 interest under section 201(14)\nof the Act is chargeable up to the date of payment of taxes by the\ndeductee/ payee. However, in the present case the Assessing

ITO (TDS) ALWAR, ALWAR vs. SHRI BABA MOHAN RAMJI KALIKHOLI WALAMILKPUR GURJAR, ALWAR

9. In view of the above discussion, all the appeals filed by the department deserve to be dismissed

ITA 746/JPR/2025[2019-20]Status: DisposedITAT Jaipur02 Sept 2025AY 2019-20

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Shri Gautam Singh Choudhary, Addl. CIT
Section 194CSection 201(1)Section 38

refund is due, even (after) tax deducted at source is counted, in such case, there is no justification for charging interest under section 201(14). CIT Vs. Rishikesh Apartments Co-operative Housing Society Ltd. 253 ITR 310 (Guj.) Where the payer failed to deduct tax but the person has paid

ITO (TDS) ALWAR, ALWAR vs. SHRI BABA MOHAN RAMJI KALIKHOLI WALAMILKPUR GURJAR, ALWAR

9. In view of the above discussion, all the appeals filed by the department deserve to be dismissed

ITA 745/JPR/2025[2018-19]Status: DisposedITAT Jaipur02 Sept 2025AY 2018-19

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Shri Gautam Singh Choudhary, Addl. CIT
Section 194CSection 201(1)Section 38

refund is due, even (after) tax deducted at source is counted, in such case, there is no justification for charging interest under section 201(14). CIT Vs. Rishikesh Apartments Co-operative Housing Society Ltd. 253 ITR 310 (Guj.) Where the payer failed to deduct tax but the person has paid

ITO (TDS) ALWAR, ALWAR vs. SHRI BABA MOHAN RAMJI KALIKHOLI WALAMILKPUR GURJAR, ALWAR

9. In view of the above discussion, all the appeals filed by the department deserve to be dismissed

ITA 744/JPR/2025[2016-17]Status: DisposedITAT Jaipur02 Sept 2025AY 2016-17

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Shri Gautam Singh Choudhary, Addl. CIT
Section 194CSection 201(1)Section 38

refund is due, even (after) tax deducted at source is counted, in such case, there is no justification for charging interest under section 201(14). CIT Vs. Rishikesh Apartments Co-operative Housing Society Ltd. 253 ITR 310 (Guj.) Where the payer failed to deduct tax but the person has paid

ITO(TDS) ALWAR, ALWAR vs. SHRI BABA MOHAN RAMJI KALIKHOLI WALAMILKPUR GURJAR, ALWAR

9. In view of the above discussion, all the appeals filed by the department deserve to be dismissed

ITA 739/JPR/2025[2017-18]Status: DisposedITAT Jaipur02 Sept 2025AY 2017-18

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Shri Gautam Singh Choudhary, Addl. CIT
Section 194CSection 201(1)Section 38

refund is due, even (after) tax deducted at source is counted, in such case, there is no justification for charging interest under section 201(14). CIT Vs. Rishikesh Apartments Co-operative Housing Society Ltd. 253 ITR 310 (Guj.) Where the payer failed to deduct tax but the person has paid

RUDRA BUILDWELL PROJECT P.LTD,DELHI vs. DCIT, CENTRAL CIRCLE, , NOIDA

Appeal is allowed

ITA 3216/DEL/2018[2011-12]Status: DisposedITAT Delhi15 Jan 2025AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2014-15 M/S. Spearsearch Solutions, Vs. Income Tax Officer, F-4 & 5, Street No. 3, Near Ward-77(3), Nathu Sweets, Laxmi Nagar, New Delhi Vikas Marg, New Delhi Pan: Abofs7069J (Appellant) (Respondent) Assessee By Sh. P.D. Mittal, Ca Department By Sh. Om Prakash, Sr. Dr

Section 194Section 194CSection 201Section 201(1)Section 250Section 44ASection 9Section 9(1)(vii)

been paid by the payee. Further the issue considered by the Assessing Officer was whether the assessee was liable to pay interest under section 201(14) of the Act. The Assessing Officer taking note of the ratio laid down by the Hon'ble Supreme Court in Hindustan Coca Cola Beverages ... Hindustan Coca Cola Beverages P. Ltd. Vs CIT (supra) and Instruction of CBDT as per its Circular No.275/201/95-IT(B) dated 29.1.1997 interest under section 201(14) of the Act is chargeable up to the date of payment of taxes by the 6 | P a g e deductee/payee. However

THE GREAT EASTERN SHIPPING CO. LTD ,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, TDS, CIRCLE 2(3), MUMBAI

In the result, all the eight appeals filed by the assessee are allowed

ITA 2778/MUM/2024[2019-20]Status: DisposedITAT Mumbai27 Nov 2024AY 2019-20

Bench: Shri Sandeep Gosain & Ms. Padmavathy S

Section 192(3)Section 201Section 220(2)Section 250

section (1) of section 192 of the Act contemplates deduction of income- tax at the time of payment and at the same time, section 201(14) deals with a situation when tax is not deducted, but sub-section (3) of section 192 is a part of section 192 required ... beyond the financial year. 5. The learned counsel for the appellants submitted that in view of the pronouncement as above, the provisions of section 201(14) of the Act would become otiose. We do not think so. Section 201(1A) applies only when during the financial year whole

THE GREAT EASTERN SHIPPING CO. LTD,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, TDS, CIRCLE 2(3), MUMBAI

In the result, all the eight appeals filed by the assessee are allowed

ITA 2777/MUM/2024[2018-19]Status: DisposedITAT Mumbai27 Nov 2024AY 2018-19

Bench: Shri Sandeep Gosain & Ms. Padmavathy S

Section 192(3)Section 201Section 220(2)Section 250

section (1) of section 192 of the Act contemplates deduction of income- tax at the time of payment and at the same time, section 201(14) deals with a situation when tax is not deducted, but sub-section (3) of section 192 is a part of section 192 required ... beyond the financial year. 5. The learned counsel for the appellants submitted that in view of the pronouncement as above, the provisions of section 201(14) of the Act would become otiose. We do not think so. Section 201(1A) applies only when during the financial year whole

THE GREAT EASTERN SHIPPING CO. LTD ,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, TDS CIRCLE 2(3), MUMBAI

In the result, all the eight appeals filed by the assessee are allowed

ITA 2776/MUM/2024[2017-18]Status: DisposedITAT Mumbai27 Nov 2024AY 2017-18

Bench: Shri Sandeep Gosain & Ms. Padmavathy S

Section 192(3)Section 201Section 220(2)Section 250

section (1) of section 192 of the Act contemplates deduction of income- tax at the time of payment and at the same time, section 201(14) deals with a situation when tax is not deducted, but sub-section (3) of section 192 is a part of section 192 required ... beyond the financial year. 5. The learned counsel for the appellants submitted that in view of the pronouncement as above, the provisions of section 201(14) of the Act would become otiose. We do not think so. Section 201(1A) applies only when during the financial year whole

THE GREAT EASTERN SHIPPING CO. LTD ,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, TDS CIRCLE 2(3), MUMBAI

In the result, all the eight appeals filed by the assessee are allowed

ITA 2775/MUM/2024[2016-17]Status: DisposedITAT Mumbai27 Nov 2024AY 2016-17

Bench: Shri Sandeep Gosain & Ms. Padmavathy S

Section 192(3)Section 201Section 220(2)Section 250

section (1) of section 192 of the Act contemplates deduction of income- tax at the time of payment and at the same time, section 201(14) deals with a situation when tax is not deducted, but sub-section (3) of section 192 is a part of section 192 required ... beyond the financial year. 5. The learned counsel for the appellants submitted that in view of the pronouncement as above, the provisions of section 201(14) of the Act would become otiose. We do not think so. Section 201(1A) applies only when during the financial year whole

THE GREAT EASTERN SHIPPING CO. LTD ,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, TDS, CIRCLE 2(3), MUMBAI

In the result, all the eight appeals filed by the assessee are allowed

ITA 2774/MUM/2024[2015-16]Status: DisposedITAT Mumbai27 Nov 2024AY 2015-16

Bench: Shri Sandeep Gosain & Ms. Padmavathy S

Section 192(3)Section 201Section 220(2)Section 250

section (1) of section 192 of the Act contemplates deduction of income- tax at the time of payment and at the same time, section 201(14) deals with a situation when tax is not deducted, but sub-section (3) of section 192 is a part of section 192 required ... beyond the financial year. 5. The learned counsel for the appellants submitted that in view of the pronouncement as above, the provisions of section 201(14) of the Act would become otiose. We do not think so. Section 201(1A) applies only when during the financial year whole

THE GREAT EASTERN SHIPPING CO. LTD,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, TDS CIRCLE 2(3), MUMBAI

In the result, all the eight appeals filed by the assessee are allowed

ITA 2773/MUM/2024[2014-15]Status: DisposedITAT Mumbai27 Nov 2024AY 2014-15
Section 192(3)Section 201Section 220(2)Section 250

section (1) of section 192 of the Act contemplates deduction of income- tax at the time of payment and at the same time, section 201(14) deals with a situation when tax is not deducted, but sub-section (3) of section 192 is a part of section 192 required ... beyond the financial year.\n5. The learned counsel for the appellants submitted that in view of the pronouncement as above, the provisions of section 201(14) of the Act would become otiose. We do not think so. Section 201(1A) applies only when during the financial year whole

THE GREAT EASTERN SHIPPING CO. LTD ,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, TDS CIRCLE 2(3), MUMBAI

In the result, all the eight appeals filed by the assessee\nare allowed

ITA 2772/MUM/2024[2013-14]Status: DisposedITAT Mumbai27 Nov 2024AY 2013-14
Section 192(3)Section 201Section 220(2)Section 250

section (1) of section 192 of the Act\ncontemplates deduction of income- tax at the time of payment and\nat the same time, section 201(14) deals with a situation when tax\nis not deducted, but sub-section (3) of section 192 is a part of\nsection 192 required ... nbeyond the financial year.\n5. The learned counsel for the appellants submitted that in view of\nthe pronouncement as above, the provisions of section 201(14) of\nthe Act would become otiose. We do not think so. Section 201(1A)\napplies only when during the financial year whole

THE GREAT EASTERN SHIPPING CO. LTD,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, TDS CIRCLE 2(3), MUMBAI

In the result, all the eight appeals filed by the assessee are allowed

ITA 2771/MUM/2024[2012-13]Status: DisposedITAT Mumbai27 Nov 2024AY 2012-13

Bench: Shri Sandeep Gosain & Ms. Padmavathy S

Section 192(3)Section 201Section 220(2)Section 250

section (1) of section 192 of the Act contemplates deduction of income- tax at the time of payment and at the same time, section 201(14) deals with a situation when tax is not deducted, but sub-section (3) of section 192 is a part of section 192 required ... beyond the financial year. 5. The learned counsel for the appellants submitted that in view of the pronouncement as above, the provisions of section 201(14) of the Act would become otiose. We do not think so. Section 201(1A) applies only when during the financial year whole

PIRAMAL CAPITAL AND HOUSING FINANCE LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX TDS - 2 (1),MUMBAI, MUMBAI

Accordingly, in terms of paragraph 13 & 17 above, all the four appeals preferred by the Assessee are allowed

ITA 2351/MUM/2024[AY 2017-18]Status: DisposedITAT Mumbai25 Nov 2024

Bench: IN THE INCOME TAX APPELLATE TRIBUNAL "C" BENCH, MUMBAI SHRI AMARJIT SINGH, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Yogesh Thar, Shri RonakFor Respondent: Ms. Madhu Malati Ghosh &
Section 191Section 193Section 194Section 194ASection 201Section 201(1)

Assessee-in-Default’ u/s 201 of the Act and hence the said order be quashed IV. Ground IV: CHARGING OF INTEREST UNDER SECTION 201(14) OF THE ACT: 1. On the facts and circumstances of the case and in law, the AG erred in levying interest u/s. 201

PIRAMAL CAPITAL AND HOUSING FINANCE LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX TDS - 2 (1), MUMBAI, MUMBAI

Accordingly, in terms of paragraph 13 & 17 above, all the four appeals preferred by the Assessee are allowed

ITA 2348/MUM/2024[AY 2018-19]Status: DisposedITAT Mumbai25 Nov 2024

Bench: SHRI AMARJIT SINGH, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Yogesh Thar, Shri RonakFor Respondent: Ms. Madhu Malati Ghosh &
Section 191Section 193Section 194Section 194ASection 201Section 201(1)

Assessee-in-Default’ u/s 201 of the Act and hence the said order be quashed IV. Ground IV: CHARGING OF INTEREST UNDER SECTION 201(14) OF THE ACT: 1. On the facts and circumstances of the case and in law, the AG erred in levying interest u/s. 201

PIRAMAL CAPITAL AND HOUSING FINANCE LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX TDS - 2 (1), MUMBAI, MUMBAI

Accordingly, in terms of paragraph 13 & 17 above, all the four appeals preferred by the Assessee are allowed

ITA 2347/MUM/2024[AY 2019-20]Status: DisposedITAT Mumbai25 Nov 2024

Bench: SHRI AMARJIT SINGH, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Yogesh Thar, Shri RonakFor Respondent: Ms. Madhu Malati Ghosh &
Section 191Section 193Section 194Section 194ASection 201Section 201(1)

Assessee-in-Default’ u/s 201 of the Act and hence the said order be quashed IV. Ground IV: CHARGING OF INTEREST UNDER SECTION 201(14) OF THE ACT: 1. On the facts and circumstances of the case and in law, the AG erred in levying interest u/s. 201

PIRAMAL CAPITAL AND HOUSING FINANCE LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX TDS - 2 (1), MUMBAI, MUMBAI

Accordingly, in terms of paragraph 13 & 17 above, all the four appeals preferred by the Assessee are allowed

ITA 2345/MUM/2024[AY 2020-21]Status: DisposedITAT Mumbai25 Nov 2024

Bench: SHRI AMARJIT SINGH, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Yogesh Thar, Shri RonakFor Respondent: Ms. Madhu Malati Ghosh &
Section 191Section 193Section 194Section 194ASection 201Section 201(1)

Assessee-in-Default’ u/s 201 of the Act and hence the said order be quashed IV. Ground IV: CHARGING OF INTEREST UNDER SECTION 201(14) OF THE ACT: 1. On the facts and circumstances of the case and in law, the AG erred in levying interest u/s. 201