VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawConcepts › The demand notice, and how long you actually have to pay

The demand notice, and how long you actually have to pay

The order has come with a notice of demand. How long do I have, and can they give me less than thirty days?

The order has come with a notice of demand. How long do I have, and can they give me less than thirty days?

Thirty days from service of the notice, under s.220(1). They can give less, but only if the Assessing Officer has reason to believe that allowing the full period would be detrimental to revenue and the Joint Commissioner has approved it beforehand. Miss the date and interest under s.220(2) starts, and you can be treated as an assessee in default.

This is an explainer, not a judgment. It states the law in our own words, which is exactly why it needs checking. Everything below was written from the sources listed at the foot of this page, and no chartered accountant has yet signed it off. Read the source before you rely on it in a reply or an appeal.

Where the demand comes from. Section 156 provides that 'When any tax, interest, penalty, fine or any other sum is payable in consequence of any order passed under this Act, the Assessing Officer shall serve upon the assessee a notice of demand in the prescribed form specifying the sum so payable'. The demand is therefore a consequence of an order; there is no free-standing demand. An intimation under s.143(1) which computes a sum payable is deemed to be a notice of demand under s.156, which is why a CPC demand needs no separate notice.

The thirty days. Section 220(1) provides that 'Any amount, otherwise than by way of advance tax, specified as payable in a notice of demand under section 156 shall be paid within thirty days of the service of the notice at the place and to the person mentioned in the notice'. Two points on the wording. The period runs from service, not from the date on the notice - so where the order was uploaded and the notice served later, the later date governs. And it is the sum specified in the notice that has to be paid; if the notice specifies a different figure from the order, that is itself a ground to have the notice corrected.

The shorter period. The proviso to s.220(1) allows the Assessing Officer, where he has reason to believe that allowing the full period of thirty days will be detrimental to revenue, to direct payment within a shorter period, with the previous approval of the Joint Commissioner. Two conditions, both prior: a recorded reason to believe, and an approval taken before the direction is issued. A notice demanding payment in seven days without either is open to challenge on that ground alone, and the approval is a document you are entitled to ask for.

What happens if the date passes. Interest under s.220(2) runs from the day immediately following the end of the period allowed under sub-section (1) until payment. You may also be treated as an assessee in default under s.220(4), with penalty under s.221 and the recovery machinery behind it - this library carries the assessee-in-default concept and the recovery entries. Interest under s.220(2) is reduced where the demand is reduced in appeal or revision, and there is a separate waiver route under s.220(2A).

What to do inside the thirty days. If an appeal is being filed, apply under s.220(6) to be treated as not in default pending the appeal; that is the only application which stops the clock on recovery, and the library holds CBDT Instruction No. 1914 and the office memoranda that govern how much has to be paid. If the demand itself is wrong on the face of the record - a missing challan, an ignored TDS credit, an arithmetical error - file a s.154 application at once and say in the s.220(6) application that it is pending. If the order is appealable, the appeal and the stay application are separate steps and both have to be taken.

A note on service. Most of the disputes about the thirty days are really disputes about service, which the library covers separately. Keep the envelope, the portal timestamp or the email header - the date on the notice is not evidence of when it was served on you.

Why it matters

The thirty days is the only window in which a demand can be dealt with cheaply. Once it passes, interest runs, the file moves to recovery, and everything after that - the stay application, the garnishee notice, the adjustment of a later refund - is harder and slower than the same application made on day five. The shorter-period proviso is also one of the few places in the recovery chapter where an internal approval is a precondition, which makes a hurried demand worth reading closely.

What to do

Where people go wrong

Unsettled, or not pinned down. The rate of interest under s.220(2) is not stated here: the department's own s.220 page, which was the source for the sub-sections, shows a rate of one and one-half per cent for every month or part of a month, which does not appear to be the current rate, and I could not reach a current bare text to confirm it. The corresponding provisions of the Income-tax Act 2025 were not checked. Nothing here deals with instalments under s.220(3) or with the position where the order is set aside and reinstated.

Authorities on these sections

Judgments in this library that turn on the same provisions.

Where this came from

Every page in this library links to what it was written from, so you can check it rather than take our word for it.