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Case lawCBDT Circulars & Instructions › Statutory position — s.211: the four advance tax instalments, and the single 15 March instalment for a s.44AD or s.44ADA presumptive assessee
CBDT Circulars & InstructionsCuts both wayss.211s.211(1)s.211(2)s.44ADs.44ADAs.234Cs.234C(1)(b)s.210s.156

Statutory position — s.211: the four advance tax instalments, and the single 15 March instalment for a s.44AD or s.44ADA presumptive assessee

My client returns income under s.44AD. The CPC has charged s.234C interest on four instalments. Is a presumptive assessee not entitled to pay the whole advance tax by 15 March?

My client returns income under s.44AD. The CPC has charged s.234C interest on four instalments. Is a presumptive assessee not entitled to pay the whole advance tax by 15 March?

He is. Section 211(1) now splits assessees into two classes: clause (a) covers 'all the assessees, other than the assessee referred to in clause (b)', who pay in four instalments — fifteen per cent by 15 June, forty-five per cent by 15 September, seventy-five per cent by 15 December and the whole by 15 March, each cumulative and reduced by earlier instalments; clause (b) covers 'an assessee who declares profits and gains in accordance with the provisions of sub-section (1) of section 44AD or sub-section (1) of section 44ADA', who pays 'to the extent of the whole amount of such advance tax during each financial year on or before the 15th March'. Section 234C(1)(b) mirrors this exactly, charging a presumptive assessee interest only on the shortfall from the tax due on the returned income as at 15 March.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2017-04-01, reported as Income-tax Act, 1961, s.211, as printed on the departmental section pages stamped Year: 2025 and Year: 2024 (No. 1); clause (1)(b) in its present form substituted by the Finance Act, 2017, s.74, operative from 1 April 2017 by force of s.1(2) of that Act. It bears on section 211, section 211(1), section 211(2), section 44AD, section 44ADA, section 234C, section 234C(1)(b), section 210, section 156 of the Income Tax Act 1961, in Presumptive Taxation & Audit, Assessment & Scrutiny and Demand, Recovery & Stay matters.

Still good law. The section is printed identically on departmental pages of two vintages (Year: 2025 and Year: 2024 (No. 1)); the -64 page was re-transcribed on verification and returned the same text, and its presumptive limb is matched by s.234C(1)(b) on the Year: 2025 s.234C page. Clause (1)(b) in its present form was substituted by s.74 of the Finance Act, 2017, in force 1 April 2017 by s.1(2) of that Act, so the position stated here governs the financial year 2017-18 onwards; for earlier years clause (b) reached only an eligible assessee in an eligible business under s.44AD and a s.44ADA professional paid in four instalments. The original insertion of clause (b) and the extension of the four-instalment schedule to non-corporate assessees could not be dated. Validity was not checked against any judicial decision.

Why it matters

Getting this wrong costs the client s.234C interest on four instalment dates instead of one, and the error is easy to make because the s.211 table looks like the whole of the section. Three practical points. First, the clause (b) route depends on the assessee actually declaring profits and gains in accordance with s.44AD(1) or s.44ADA(1) — it is keyed to the basis on which the income is returned, not merely to eligibility, so an eligible assessee who returns his real profits under the normal provisions falls back into clause (a) and its four instalments. Second, clause (b) is confined to those two sub-sections; it does not on its words extend to s.44AE, s.44B, s.44BB or s.44BBB, and an assessee under those provisions pays in four instalments. The date matters as much as the wording. Clause (b) in its present form was substituted by s.74 of the Finance Act, 2017, which replaced the earlier words "an eligible assessee in respect of an eligible business referred to in section 44AD" with the present formula covering s.44AD(1) and s.44ADA(1); s.75 of the same Act made the mirror substitution in s.234C(1)(a) and (1)(b). By s.1(2) of that Act, sections 2 to 88 came into force on 1 April 2017. So for the financial year 2016-17 and earlier, clause (b) reached only an eligible assessee in an eligible business under s.44AD, and a s.44ADA professional was in clause (a) on four instalments — do not apply the present single-instalment rule to that year. Third, the proviso to s.211(1) is easy to miss and is worth real money: 'any amount paid by way of advance tax on or before the 31st day of March shall also be treated as advance tax paid during the financial year ending on that day for all the purposes of this Act', so a payment made between 16 and 31 March is still advance tax — it does not cure the s.234C shortfall at 15 March, but it is advance tax for s.234B and for s.219 credit rather than self-assessment tax. Section 211(2) deals separately with the case where a s.156 notice under a s.210(3) or (4) order is served after a due date: the tax is then payable on such of the due dates as fall after service.

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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