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2023 (4) TMI 726 - AT - Income TaxInterest u/s 234A - what is the period upto which interest u/s 234A can be levied? - HELD THAT:- As the interest u/s 234A is a monetary compensation against the legitimate taxes due to the Government of India, we in the light of “CIT Vs Prannoy Roy” [2008 (9) TMI 150 - SUPREME COURT] are of the considered view that, irrespective of date of filing of ITR, interest u/s 234A of the Act, shall on the balance of taxes outstanding accrue commencing from the first date immediately following the due date and shall cease to accrue on the date of payment by instalment (when paid in parts) or on the date of full discharge of entire tax liability computed on the total income. It shall be needless to mentioned that, by virtue of provisions of sub-section (2) to section 243A, the interest payable under sub-section (1) shall be reduced by the interest, if any, paid u/s 140A towards the interest chargeable thereunder. In the extant appeal, since the appellant in terms of section 234A(1) computed the interest accrued on each occasion of payment by instalment on the outstanding balance of taxes due to ex-chequer and discharged the entire tax liability alongwith interest accrued thereon before filing of his return, we finding no fault with the computation of interest liable u/s 234A, hold the orders of both the Ld. TAB as erroneous, consequently we set-aside the order of Ld. NFAC and direct the Ld. CPC to compute interest in aforestated terms - Assessee appeal allowed.
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