TMI Blog2016 (2) TMI 1239X X X X Extracts X X X X X X X X Extracts X X X X ..... and not British calendar month as defined under section 3(35) of General Clauses Act. Similar view has been taken in the case of Oil Natural Gas Commission vs. ACIT (TDS), Surat, [ 2015 (10) TMI 1006 - ITAT AHMEDABAD] wherein it was held that levy of interest u/s 201(1A) is compensatory in nature and thus gap of time between point of time when tax ought to have been deducted at sources vis- -vis point of time when tax was actually deducted are to be seen and it is in this context that connotation of expression month is to be examined. In view of aforesaid decisions, we do not find any infirmity in the order of the CIT(A) which is hereby upheld. - ITA Nos. 2931 to 2933, 2934/Ahd/2015 Assessment Year: 2013-14 to 2015-15 - - - Da ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 945112 2932/Ahd/2015 2014-15 26Q Q1 103203 14616 158685 2014-15 26Q Q4 690014 21420 327492 445311 2933/Ahd/2015 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hether, for the purpose of levy of interest u/s 201(1A), the term month could be given ordinary sense, i.e., a period of 30 days or whether it could be treated as British Calendar Month as per General Clauses Act. The Assessing Officer worked out amount of interest u/s 201(1A) based on British Calendar month, whereas CIT(A) directed the Assessing Officer to work out interest by adopting period of 30 days as one month. I find that this issue is squarely covered in favour of the assessee by the decision of Hon ble Gujarat High Court in the case of CIT vs. Arvind Mills Ltd, reported in 16 taxmann.com 291 (Guj), wherein Hon ble Court has held that for the purposes of Section 244A, term month must be given ordinary sense of term, i.e., ..... X X X X Extracts X X X X X X X X Extracts X X X X
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