ARVINDPAL SINGH, YAMUNA NAGAR,YAMUNA NAGAR V. JAO THE INCOME TAX OFFICER WARD-1, YAMUNA NAGAR, YAMUNA NAGAR

ITA 1300/CHANDI/2025

AI Insights

The case involves Arvindpal Singh, the appellant, who filed an appeal against the order of the CIT(A) confirming the addition/adjustment of higher interest amounts under sections 234A, 234B, and 234C as computed by the CPC, Bengaluru. The appellant argued that the interest was incorrectly calculated up to the date of processing rather than the date of filing the return. The Tribunal considered the submissions and decided to remand the case back to the Assessing Officer for a thorough re-examination of the interest calculations, adhering to legal provisions and ensuring fair opportunity for the appellant to present his case.

• Counselvise Citation: [2026] 140 COUNSELVISE.COM (IT) 836528 (ITAT-CHANDIGARH)
• Duration Of Justice: 4 month(s) 3 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 13-02-2026
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: A
• Assessment Year: 2022-2023
• Appeal Filed On: 10-10-2025
• Laws Referred To: Income Tax Act
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: VIVEK VARDHAN
• Assessee Lawyers: SUDHIR SEHGAL
• Section: 234B

Judgement Text

" आयकर अपीलȣय अͬधकरण, चÖडीगढ़ Ûयायपीठ, चÖडीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL CHANDIGARH BENCH, ‘A’, CHANDIGARH BEFORE SHRI LALIET KUMAR, JUDICIAL MEMBER & SHRI KRINWANT SAHAY, ACCOUNTANT MEMBER आयकर अपील सं./ ITA No. 1300/CHD/2025 Ǔनधा[रण वष[ / Assessment Year : 2022-23 Arvindpal Singh, 1314, Jamna Street, Yamunanagar 135001 बनाम Vs. The JAO/ITO, Warad-1 Yamunanagar èथायी लेखा सं./ PAN NO: AQEPS7618E अपीलाथȸ/Appellant Ĥ×यथȸ/Respondent ( PHYSICAL HEARING ) Ǔनधा[ǐरती कȧ ओर से/Assessee by : Sh. Sudhir Sehgal, Advocate राजèव कȧ ओर से/ Revenue by : Sh. Vivek Vardhan, Addl. CIT Sr.DR सुनवाई कȧ तारȣख/Date of Hearing : 12.02.2026 उदघोषणा कȧ तारȣख/Date of Pronouncement : 13.02.2026 आदेश/Order Per Krinwant Sahay, AM : Appeal in this case has been filed by the assessee against the order dated 18.08.2025 passed by the Ld. Addl. / JCIT(A), Thane. 2. Grounds of appeal, as raised by the Assessee are reproduced as under: Printed from counselvise.com 1300-Chd-2025 2 1.1 That the Ld. CIT(A) has erred in confirming the addition/adjustment of higher amount interest u/s 234A, 2348 and 234C as made by the CPC, Bengaluru against the interest disclosed by the assessee while filing ITR- U. 1.2 That the CIT(A) has erred in not considering the fact that the CPC, Bengaluru have computed interest upto the date of processing of the Income Tax Return and not upto the date of filing of such return. 2. That the appellant craves leave to add or amend the grounds of appeal before the appeal is finally heard or disposed off. 5. At the very outset, the ld. Counsel of the Assessee submitted before the Bench that the Ld. CIT(A) has confirmed the addition / adjustment of higher amount interest u/s 234A, 234B and 234C, as made by the CPC Bangaluru against the interest disclosed by the Assessee while filing ITR-U. It has further been submitted that the Ld. CIT(A) has not taken into consideration the fact that the CPC has computed the interest upto the date of processing of I.T. Return and not upto the date of filing of such return and as such the confirmation of addition by the Ld. CIT(A) is not in order. A prayer has been made to Printed from counselvise.com 1300-Chd-2025 3 remand the matter back to the lower authorities for deciding the matter as per law. 6. Per contra, ld. DR relied on the orders of the authorities below. 7. We have considered the findings given by the authorities below and the submissions as well as arguments of the ld. DR. We are of this considered view that in the fitness of things, the matter should be remanded back to the file of the Assessing Officer with a direction to verify the claim of the Assessee as per law and making adjustment of interest after giving due and adequate opportunity to the Assessee as required under the law. 8. Accordingly, the case is remanded back to the file of the AO for adjudication afresh on merit, by considering the submissions, documentary evidence produced by the Assessee and the relevant material available on record. Needless to say, that the Assessing Officer shall afford due, reasonable and adequate opportunity of hearing to the Assessee. The Assessee, no doubt, shall cooperate in Printed from counselvise.com 1300-Chd-2025 4 the proceedings before the Assessing Officer. All pleas available under the law shall remain so available to the assessee. Ordered accordingly. 9. In the result, Assessee’s appeal is allowed for Statistical Purposes. Order Pronounced on 13.2.2026. Sd/- Sd/- ( LALIET KUMAR ) ( KRINWANT SAHAY) Judicial Member Accountant Member “आर.क े.” आदेश कȧ ĤǓतͧलͪप अĒेͪषत / Copy of the order forwarded to : 1. अपीलाथȸ/ The Appellant 2. Ĥ×यथȸ/ The Respondent 3. आयकर आयुÈत/ CIT 4. ͪवभागीय ĤǓतǓनͬध, आयकर अपीलȣय आͬधकरण, चÖडीगढ़/ DR, ITAT, CHANDIGARH 5. गाड[ फाईल/ Guard File सहायक पंजीकार/ Assistant Registrar Printed from counselvise.com "