Shruti Shibulal Vs DCIT (TAT Bangalore)
When Infosys-Developed Tax Software Taxed an Infosys Promoter’s Family Wrongly: ITAT Cuts Section 234C Interest from ₹7 Lakh to ₹56,047
Summary: The assessee, Shruti Shibulal, was an individual resident in India having income from house property, capital gains & other sources, including income arising in the United States of America. The assessee filed the original return on 18 August 2018 declaring total income of ₹42,19,74,290. A revised return was subsequently filed u/s 139(5) on 30 March 2019 declaring income of approximately ₹43.70 crore.
The assessment was completed u/s 143(3) r.w.s. 143(3A) & 143(3B) on 10 February 2021. The returned income was substantially accepted. The dispute was confined to computation of interest for deferment of advance tax u/s 234C.
The assessee had computed interest u/s 234C at ₹56,047 & paid it along with self-assessment tax. However, the AO’s computation determined interest at ₹7,00,499, resulting in an additional demand. The order did not disclose the calculation or basis on which the much higher figure had been arrived at.
The assessee challenged the levy before the CIT(A), but the appeal was dismissed. The assessee therefore approached the Bangalore Tribunal.
Issue before the Tribunal
The sole issue was whether interest u/s 234C was correctly chargeable at ₹7,00,499, as computed by the AO, or whether it should be restricted to ₹56,047, as calculated & already paid by the assessee.
