Sporta Technologies Private Limited Vs A/JCIT (ITAT Mumbai)
The Mumbai Bench of the Income Tax Appellate Tribunal examined an appeal challenging the levy of interest under Section 234C of the Income-tax Act, 1961, for the Assessment Year 2024–25. The interest was levied on the ground that the third instalment of advance tax was allegedly paid after the prescribed due date. The assessee contended that the advance tax was paid electronically through net banking on 15 December 2023, which was the statutory due date, and the amount was debited from its bank account on the same day. However, due to a technical or system-related delay, the challan was generated on 16 December 2023, leading the Centralized Processing Centre to treat the payment as delayed and levy interest of ₹1.23 crore under Section 234C.
The Tribunal noted that it was undisputed that the advance tax amount was debited from the assessee’s bank account on 15 December 2023, as reflected in the bank statement, and that the challan generated on 16 December 2023 bore the same bank reference number. The Tribunal held that the assessee had initiated and completed the payment process within the statutory due date and that the subsequent generation of the challan on the next day was not attributable to the assessee. The Tribunal observed that in cases of electronic payment, once the amount is debited from the taxpayer’s bank account within the due date, the payment must be treated as having been made on that date, irrespective of when the challan is generated or the amount is credited to the government account.
