VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — s.210(3) to (6): the Assessing Officer's order to pay advance tax, the assessee's own lower estimate in Form 28A, and s.218 default
CBDT Circulars & InstructionsCuts both waysValidity unconfirmeds.210s.210(3)s.210(4)s.210(5)s.210(6)s.218s.209s.209(1)(b)s.211s.156

Statutory position — s.210(3) to (6): the Assessing Officer's order to pay advance tax, the assessee's own lower estimate in Form 28A, and s.218 default

The Assessing Officer has served an order in February requiring my client to pay advance tax on the basis of an earlier year's assessed income. Can he do that, and what can my client do if the current year's income will be far lower?

The Assessing Officer has served an order in February requiring my client to pay advance tax on the basis of an earlier year's assessed income. Can he do that, and what can my client do if the current year's income will be far lower?

He can, but only within the limits s.210(3) sets: the power exists only where the person has already been assessed by way of regular assessment for some previous year, it must be exercised 'at any time during the financial year but not later than the last day of February', it must be by order in writing, the tax must be calculated in the manner laid down in s.209, and a notice of demand under s.156 specifying the instalments must issue. If the current income will be lower, s.210(5) lets the assessee send an intimation in the prescribed form — Form No. 28A under rule 39 — and pay according to his own estimate instead; if it will be higher, s.210(6) obliges him to pay the higher amount by the last instalment date without waiting to be asked.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2025-04-01, reported as Income-tax Act, 1961, ss.210 and 218, as printed on the departmental section pages stamped Year: 2025, with s.210(3) to (6) corroborated on the page stamped Year: 2024 (No. 1). It bears on section 210, section 210(3), section 210(4), section 210(5), section 210(6), section 218, section 209, section 209(1)(b), section 211, section 156 of the Income Tax Act 1961, in Assessment & Scrutiny, Demand, Recovery & Stay and How Tax Law Is Read matters.

Validity check could not be completed. Validity check could not be completed. Section 210(3) to (6) is printed identically on departmental pages of two vintages (Year: 2025 and Year: 2024 (No. 1)), which is good evidence that the text is current, s.218 is now printed identically on two departmental pages of different vintage (Year: 2025 and Year: 2024 (No. 1)), but no footnote apparatus rendered on either section so no amendment could be dated, and the form number in rule 39 could be sourced only from indiankanoon's copy of the Rules, which the governing brief treats as unreliable for currency. No judicial decision on s.210 or s.218 was retrieved this pass.

Why it matters

Section 210 is the only part of the advance tax machinery that produces a demand the assessee can be in default on before the year is even over, and it is full of conditions that are easy to breach and easy to miss. The February cut-off in s.210(3) is absolute on the words used, so an order made in March is outside the power. The jurisdictional fact is a completed regular assessment for some previous year, which means a person never so assessed cannot be brought under s.210(3) at all — although he remains liable under s.210(1) of his own accord. The basis of the officer's computation is fixed by s.209(1)(b): the higher of the total income of the latest previous year assessed by regular assessment and the total income returned for any subsequent previous year — he may not use an estimate of his own. Section 210(4) allows an amended order if, before 1 March, a return is filed or a later regular assessment is made, again with a fresh s.156 notice. The assessee's answers are s.210(5) — a downward intimation in Form 28A, after which he pays on his own estimate — and s.210(6), which is mandatory in its terms ('shall') where his estimate is higher. The sanction is s.218: failure to pay an instalment under a s.210(3) or (4) order, coupled with failure to send the s.210(5) intimation on or before the date the unpaid instalment falls due or to pay under s.210(6), makes the assessee 'deemed to be an assessee in default in respect of such instalment or instalments' — which opens Chapter XVII-D recovery.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

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