Rule 269 — Procedure to be followed in calculating interest under section 533(2)(u). Made under s.533 of the Income-tax Act, 2025.
Rule 269 gives effect to Section 533 of the Income-tax Act, 2025. A rule cannot go beyond the section it serves: where the two seem to differ, the section governs.
Rule 269 prescribes three rounding conventions that apply in calculating interest payable by the assessee, or interest payable by the Central Government to the assessee, under any provision of the Act.
Clause (a) governs the period where interest is calculated on an annual basis: the period is rounded off to a whole month or months, any fraction of a month is ignored, and the period so rounded off is deemed to be the period in respect of which the interest is to be calculated.
Clause (b) governs the period where interest is calculated for every month or part of a month comprised in a period: any fraction of a month is deemed to be a full month and the interest is calculated accordingly.
Clause (c) governs the base: the amount of tax, penalty or other sum on which the interest is calculated is rounded off to the nearest multiple of Rs. 100, any fraction of Rs. 100 is ignored, and the amount so rounded off is deemed to be the amount in respect of which the interest is to be calculated.
Interest under the Act is charged and paid under many different provisions, and each of them would otherwise raise the same three questions — what to do with a part month, whether the answer differs when the provision itself says "month or part of a month", and how to treat the odd rupees in the principal. The rule answers all three once, for every interest provision in the Act, so that two officers computing the same interest reach the same figure.
| What | Figure | The condition on it | Where |
|---|---|---|---|
| Rounding of the period where interest is calculated on an annual basis | Rounded off to a whole month or months | Any fraction of a month is ignored; the rounded period is deemed to be the period for which interest is calculated | Clause (a) |
| Rounding of the period where interest runs for every month or part of a month | Any fraction of a month is deemed to be a full month | Applies where the interest provision itself is framed for every month or part of a month comprised in a period | Clause (b) |
| Rounding of the amount on which interest is calculated | Rounded off to the nearest multiple of Rs. 100 | Any fraction of Rs. 100 is ignored; applies to the tax, penalty or other sum in respect of which the interest is calculated | Clause (c) |
Clauses (a) and (b) pull in opposite directions and the reader has to know which provision he is under before applying either. Where the interest is on an annual basis a part month is ignored, which shortens the period; where the provision runs for every month or part of a month a part month is treated as a whole one, which lengthens it. Applying clause (b) to an annual-basis computation overstates the interest, and applying clause (a) to a month-or-part-of-a-month provision understates it. Clause (c) works on the base rather than the period, and it always works downwards — the fraction of Rs. 100 is ignored, not rounded to the nearer hundred, despite the phrase "nearest multiple". The rule is even-handed as to direction of payment: it applies to interest payable by the assessee and to interest the Central Government pays the assessee. It fixes no rate and no period of charge; those come from the interest provision itself.
Interest is to be calculated on a sum of Rs 2,47,860 for a period of four months and eleven days under a provision framed for every month or part of a month. Clause (c) reduces the base to Rs 2,47,800, the fraction of Rs 100 being ignored. Clause (b) treats the eleven days as a full month, so interest runs for five months. Had the provision instead been on an annual basis, clause (a) would have ignored the eleven days and the period would have been four months.
A reader meets it inside any interest computation in an assessment, an intimation, a demand notice or a refund order — it is not a rule anyone applies on its own, but it decides the last figure of almost every interest calculation under the Act.
the period for which such interest is to be calculated shall be rounded off to a whole month or months and for this purpose any fraction of a month shall be ignored
any fraction of a month shall be deemed to be a full month and the interest shall be so calculated
shall be rounded off to the nearest multiple of Rs. 100 and for this purpose any fraction of Rs. 100 shall be ignored