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Issues involved: Appeal against orders of ld. CIT(A) confirming orders u/s 201(1) and 201(1A) of the Income-tax Act, 1961 challenging interest for default u/s 201(1A) on grounds of TDS deposit timing and Revenue's appreciation of explanations.
Issue 1: Challenge of interest for default u/s 201(1A) on the basis of timely TDS deposit. The assessee claimed timely TDS deposit through bank challan, but the DCIT (TDS) levied interest under section 201(1A) on delayed payment period. The ld. CIT(A) upheld the interest levy citing Rule 20(i) of Receipts and Payments Rule, determining the date of payment based on the date in the challan. Various case laws were referenced to support the validity of interest levy under section 201(1A). The Tribunal found no infirmity in the ld. CIT(A)'s order and confirmed it, leading to the dismissal of the appeals. Issue 2: Interpretation of payment date for TDS deposit. In one case, the assessee claimed to have deposited a specific amount on a certain date, while the DCIT (TDS) considered a different date based on the challan. The ld. CIT(A) relied on Receipt and Payment Rule effective from 1.6.1983 to determine the payment date. The Tribunal, after examining the facts and the ld. CIT(A)'s order, upheld the interest levy due to the delay in TDS deposit, confirming the ld. CIT(A)'s decision. Significant Phrases: - Interest for default u/s 201(1A) - Timely TDS deposit - Rule 20(i) of Receipts and Payments Rule - Date of payment determination - Case laws referencing - Confirmation of ld. CIT(A)'s order - Dismissal of appeals
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