Section 215 — the law in short
What the courts have decided on section 215, in one screen. Read this first; open an entry when you need the facts, the reasoning and the source.
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Bhura Mal Raj Mal v CIT
High CourtHelps taxpayer
The officer has passed a s.154 order shifting my TDS credit to the next year because the payer's accounting year is different from mine. Can he do that by rectification?
No. The Rajasthan High Court held that the credit belongs to the year in which the income is assessed in the recipient's hands, not the year fixed by the payer's accounting year or the date on the certificate, and in any event the point was at best debatable, so s.154 could not be used at all. The consequential withdrawal of s.214 interest and charging of s.215 interest also fell.
Listed strongest first: Supreme Court, then High Court, then Tribunal, then CBDT. Nothing here has yet been read in full by a chartered accountant — open an entry to see where it came from.