Ahmed Shareef v. Dy. CIT (2021) 189 ITD 522 (Bang.)(Trib.)

S. 234A : Interest-Default in furnishing return of income-Search and seizure-the interest u/s. 234B is to be levied only on the additional tax levied on the enhanced income determined u/s. 153A, r.w.s.143 of the Act. [S. 143(3), 153A 234B]

With regard to levy of interest u/s.234A and 234B of the Act, the Tribunal held that interest u/s. 234A is chargeable from the date of expiry of the Notice period given u/s. 153A of the Act to the date of completing the assessment u/s. 153A r.w.s. 143(3) of the Act u/s. 139 of the Act. It further held that the interest u/s. 234B is to be levied only on the additional tax levied on the enhanced income determined u/s. 153A, r.w.s.143 of the Act and therefore the period of charge should be from the date of determination of income u/s. 143(3) r.w.s. 153A to the determination of increased total income u/s. 153A, r.w.s. 143(3) of the Act.  (AY. 2013-14, 2014-15, 2016-17)