VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — the first proviso to s.234C(1): no interest for a shortfall caused by capital gains, casual income, first-year business income or dividend income
CBDT Circulars & InstructionsCuts both wayss.234Cs.234C(1)s.234C(1)(b)s.2(24)(ix)s.2(22)s.115BBDAs.211s.44ADs.44ADA

Statutory position — the first proviso to s.234C(1): no interest for a shortfall caused by capital gains, casual income, first-year business income or dividend income

My client sold a property in February and paid the whole tax on it with the March instalment. The intimation still charges s.234C interest on the June, September and December instalments. Is there a defence in the section itself?

My client sold a property in February and paid the whole tax on it with the March instalment. The intimation still charges s.234C interest on the June, September and December instalments. Is there a defence in the section itself?

Yes, and it is in the section itself rather than in any circular. The first proviso to s.234C(1) disapplies the sub-section to any shortfall in the payment of tax due on the returned income where the shortfall is on account of under-estimate or failure to estimate (a) the amount of capital gains, (b) income of the nature referred to in s.2(24)(ix) — casual income such as winnings from lotteries, crossword puzzles and races, (c) income under the head 'Profits and gains of business or profession' in cases where the income accrues or arises under that head for the first time, or (d) the amount of dividend income. The relief is conditional: the assessee must have paid the whole of the tax payable in respect of that income, computed as if it were part of the total income, as part of the remaining instalments of advance tax which are due, or where no such instalments are due, by 31 March of the financial year.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2021-04-01, reported as Income-tax Act, 1961, s.234C(1), first proviso, as printed on the departmental section pages stamped Year: 2025, Year: 2023, Year: 2022 and Year: 2021; clause (d) in its present form substituted, and Explanation 2 inserted, by the Finance Act, 2021, s.59, operative from 1 April 2021 by force of s.1(2) of that Act. It bears on section 234C, section 234C(1), section 234C(1)(b), section 2(24)(ix), section 2(22), section 115BBDA, section 211, section 44AD, section 44ADA of the Income Tax Act 1961, in Capital Gains, Assessment & Scrutiny and Demand, Recovery & Stay matters.

Still good law. The proviso in the form set out above is printed identically on four departmental pages spanning Year: 2021 to Year: 2025, which is the strongest evidence available this pass that it is current. The earlier form of clause (d), referring to income of the nature in s.115BBDA(1), was inserted by s.75 of the Finance Act, 2017 with effect from 1 April 2017 and substituted by the present words, with Explanation 2 added, by s.59 of the Finance Act, 2021 with effect from 1 April 2021; both dates were established from the Finance Act texts and their s.1(2) commencement clauses, not from a departmental footnote, because no footnote apparatus rendered. The narrow form accordingly governs AY 2017-18 to AY 2020-21 and is superseded by amendment from AY 2021-22. Validity was not checked against any judicial decision.

Why it matters

This is the one provision that makes a lumpy, unforeseeable receipt survivable, and its conditions are strict. Four points decide most disputes. First, the relief is for a shortfall 'on account of' the under-estimate or failure to estimate one of the four listed items, so the shortfall attributable to ordinary, foreseeable income is not covered and interest on that part stands. Second, the payment must be made in the remaining instalments that fall due after the income arises — a capital gain earned in July and paid for only in March does not qualify for the September and December dates, because those instalments were still to come. Third, where no instalment remains, the outer limit is 31 March of the financial year, not the due date for filing the return; a payment as self-assessment tax in July of the assessment year is too late. Fourth, clause (d) as the section now reads is 'the amount of dividend income' at large, and Explanation 2 to the section provides that 'dividend' has the meaning in s.2(22) but shall not include sub-clause (e) — so deemed dividend by way of a loan or advance to a substantial shareholder is outside the relief. The dates on clause (d) decide which form applies. Clause (d) was first inserted, in the narrow form "income of the nature referred to in sub-section (1) of section 115BBDA", by s.75 of the Finance Act, 2017, in force 1 April 2017; it was substituted by the present words "the amount of dividend income", and Explanation 2 was inserted, by s.59 of the Finance Act, 2021, in force 1 April 2021 by s.1(2) of that Act. So the narrow 115BBDA form governs assessment years 2017-18 to 2020-21 — the life of s.115BBDA itself — and the wide "amount of dividend income" form governs assessment year 2021-22 onwards, which is exactly when dividend became taxable in the shareholder's hands. The governing brief for this batch described clause (d) as covering "s.115BBDA dividend"; that was right for AY 2017-18 to AY 2020-21 and is wrong for every year from AY 2021-22, and anyone applying the narrow form to a recent year will refuse a client relief the section now gives.

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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