VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — ss.215, 216 and 217: the advance tax interest scheme that ran before s.234B and s.234C, and the s.215(4) waiver power
CBDT Circulars & InstructionsCuts both waysValidity unconfirmeds.215s.215(4)s.215(5)s.215(6)s.216s.217s.209As.212s.213s.273s.234Bs.234C

Statutory position — ss.215, 216 and 217: the advance tax interest scheme that ran before s.234B and s.234C, and the s.215(4) waiver power

I am defending an old assessment year, or a reassessment for one, and the order charges interest under s.215 or s.217 rather than s.234B. What do those sections actually require, and can the interest be waived?

I am defending an old assessment year, or a reassessment for one, and the order charges interest under s.215 or s.217 rather than s.234B. What do those sections actually require, and can the interest be waived?

Sections 215, 216 and 217 are the interest provisions that preceded s.234B and s.234C, and they are all keyed to estimates under s.209A or s.212 — both of which were omitted by the Direct Tax Laws (Amendment) Act, 1987 with effect from 1 April 1988, while s.234C(2) provides that s.234C applies to assessments for the assessment year commencing on 1 April 1989 and subsequent years. Section 215(1) charges simple interest at fifteen per cent per annum where advance tax paid on the assessee's own estimate is less than seventy-five per cent of the assessed tax (eighty-three and one-third per cent for a company), from 1 April following the financial year to the date of the regular assessment; s.216 charges interest at the same rate where the assessee under-estimated and thereby reduced either of the first two instalments, or wrongly deferred payment under s.213; and s.217 charges it where no statement or estimate was sent at all. Section 215(4) — applied to s.217 by s.217(2) — gives the Assessing Officer power to 'reduce or waive the interest payable by the assessee under this section' in such cases and circumstances as may be prescribed.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2025-04-01, reported as Income-tax Act, 1961, ss.215, 216 and 217, as printed on the departmental section pages stamped Year: 2025, with s.215(1), (4), (5) and (6) corroborated on the page stamped Year: 2024 (No. 1). It bears on section 215, section 215(4), section 215(5), section 215(6), section 216, section 217, section 209A, section 212, section 213, section 273, section 234B, section 234C of the Income Tax Act 1961, in Assessment & Scrutiny, Demand, Recovery & Stay and Reassessment & Reopening matters.

Validity check could not be completed. Validity check could not be completed. Sections 215, 216 and 217 remain on the statute book and are printed in the terms set out above on the Year: 2025 departmental pages, but they operate on estimates under s.209A and s.212, both of which the departmental pages record as omitted by the Direct Tax Laws (Amendment) Act, 1987 with effect from 1 April 1988, and s.234C(2) applies the successor scheme from the assessment year commencing 1 April 1989. I did not retrieve any provision expressly limiting ss.215 to 217 to assessment years up to 1988-89, and I could not retrieve rule 40 of the Income-tax Rules, 1962, so the current status of the prescribed waiver circumstances is unknown. Each of ss.215, 216 and 217 is now printed identically on two departmental pages of different vintage (Year: 2025 and Year: 2024 (No. 1)), and every rate and percentage in this entry was corroborated on both.

Why it matters

The library covers assessment years in which this scheme applied, and courts continue to cite it on the discretion point and on what 'assessed tax' means. Four features repay attention. First, s.215(5) defines 'assessed tax' for ss.215, 217 and 273 as the tax determined on regular assessment reduced by tax deductible under an enumerated and closed list of TDS sections — ss.192 to 194, 194A, 194C, 194D, 195 and 196A — so far as it relates to income subject to advance tax; that list is materially narrower than the Explanation 1 definition used for s.234B, and the difference has been argued as decisive in s.234B litigation. Second, s.215(3) makes the interest follow the assessment: where the amount on which interest was payable is increased or reduced by an order under s.147, 154, 155, 250, 254, 260, 262, 263, 264 or a Settlement Commission order under s.245D(4), the interest is increased or reduced accordingly, with a fresh notice of demand deemed to be under s.156 in the first case and a refund of excess interest in the second. Third, s.215(6) deems a first-time assessment made under s.147 to be a regular assessment for the purposes of ss.215, 216, 217 and 273 — which is how interest attaches on a reassessment where no assessment had been made before. Fourth, s.216 is discretionary in form ('he may direct'), unlike s.234B and s.234C, which are automatic; and its Explanation deems an instalment due before six months from the commencement of the previous year to have become due fifteen days after that six months.

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

Not yet CA-verified. This entry was found through the sources listed under the Sources tab, and the summary reflects what those sources say. Nobody has yet read the full judgment and signed it off. Check the source before relying on it.

Read aloud by your device. Press again to stop.

Related

Other authorities on the same sections.