| Commissioner of Income-tax v. Atlas Cycle Industries, 180 ITR 319 (Punjab & Haryana HC) |
Held that section 215 interest is not leviable where advance tax has been paid within the financial year even if after accounting year or instalment dates. |
Cited as part of the preponderance of High Court authority supporting the assessee's contention that payment within the financial year negates section 215 interest; relied upon to quash the section 215 demand. |
| Commissioner of Income-tax v. Surajbhan Mahawar, 45 ITR 252 (Calcutta HC) |
Same proposition: payments made within the financial year are to be deemed payments of advance tax for purposes of section 215. |
Included among the authorities establishing that late payments within the financial year do not attract section 215 interest; used to support quashing of interest under s.215. |
| Commissioner of Income-tax M.P. v. Jagannath Narayan Kutumbik Trust, 144 ITR 526 (Madhya Pradesh HC) |
Followed the view that payment within the financial year prevents levy of interest under section 215. |
Part of the line of High Court decisions relied on to interpret section 215 in favour of the assessee. |
| Commissioner of Income-tax v. T.T. Investments & Trades Pvt. Ltd., 148 ITR 347 (Madras HC) |
Affirmed the principle that payment within the financial year obviates section 215 interest. |
Relied upon by the Court as supporting precedent for the assessee's interpretation of s.215. |
| Anup Engineering Ltd. v. Income-tax Officer, 145 ITR 104 (Gujarat HC) |
Conforms to the view that advance tax paid within the financial year is to be treated as payment for section 215 purposes. |
Included among supporting High Court authorities for the assessee's position on s.215. |
| Orissa Ceramic Sales v. Income-tax Officer, 145 ITR 464 (Orissa HC) |
Same principle regarding section 215 and payments within the financial year. |
Counted among the judicial authorities relied upon by the petitioner and accepted by the Court for quashing s.215 demand. |
| Commissioner of Income-tax, Karnataka-II v. T. Gopal Bhandary, 159 ITR 828 (Karnataka HC) |
Held that section 215 is not attracted where advance tax is paid within the financial year. |
Relied upon as part of the consistent judicial trend favouring the assessee's interpretation of s.215. |
| Commissioner of Income-tax, Bombay City-V v. Traub (India) P. Ltd., 118 ITR 525 (Bombay HC) |
Held similar view on non-leviability of section 215 interest if advance tax is paid within the financial year. |
Part of the body of High Court decisions relied upon in favour of the petitioner on s.215. |
| Pfizer Limited v. K. N. Anantharama Aiyar, Commissioner of Income-tax, 163 ITR 461 |
Also cited as supporting authority on the interpretation of section 215. |
Included among decisions forming the preponderance of authority persuading the Court to quash the s.215 demand. |
| Santha S. Shenoy v. Union of India and others, 135 ITR 39 (Kerala HC) |
Included in the list of High Court decisions supporting the assessee's interpretation of s.215. |
Counted as part of the line of authority relied upon to interpret s.215 in favour of the assessee. |
| Commissioner of Income-tax v. P. Ramagouda Satyam Reddy and Co., 172 ITR 491 (Andhra Pradesh HC) |
Another High Court decision cited for the same principle on section 215. |
Referenced as supporting authority in the Court's consideration of s.215. |
| Central Provinces Manganese Ore Co. Ltd. v. Commissioner of Income-tax, 160 ITR 961 (Supreme Court) |
Held that an order demanding or charging interest is not appealable under section 246(c) unless the assessee disputes that he is liable to the levy at all; interest levy is part of the process of assessment, and challenges to liability may be open in appeal if framed as non-liability. |
Relied upon by the Court to reject the Department's maintainability objection and to conclude that no alternative statutory remedy barred the writ insofar as the interest demand was concerned; used to justify hearing the petition on merits. |
| Commissioner of Income-tax, Delhi-II v. Mahabir Parshad and Sons, 125 ITR 165 (Delhi HC) |
Division bench held that an appeal agitating charging of interest can be competent if the levy is part of the assessment order, but an appeal will not lie against a separate order levying interest alone. |
Used to support the Court's conclusion on the non-availability of an alternative appeal remedy against the separate demand notice for interest. |
| L. Hirdey Narain v. Income-tax Officer, A Ward, Bareily, 78 ITR 26 (Supreme Court) |
Held that failure to move a revision application does not automatically justify dismissal of a writ petition as not maintainable; the High Court may entertain the writ petition and hear it on merits in appropriate cases. |
Cited by the Court to justify proceeding to hear and decide the writ petition on merits despite the Department's contention about alternative remedies. |
| K. P. Abdul Kareem Hajee v. Income-tax Officer, 141 ITR 120 (Kerala HC) |
Held that an order of a judicial/quasi-judicial authority is not final during the period permitted for filing an appeal or while an appeal is pending; absent statutory provision to the contrary or an interim stay, such orders are provisionally executable and may be restored; section 220(2) could be attracted on restoration. |
Relied upon by the respondent and accepted by the Court as persuasive authority for the proposition that an earlier demand can revive on finality of an appellate order, thereby supporting application of section 220(2). |
| Income-tax Officer v. A. V. Thomas & Company, 160 ITR 818 (Kerala HC) |
Distinguished on facts: where tax was paid in response to a section 156 notice and later reduced by AAC and refunded, upon Tribunal restoring the original assessment interest would not be levied on the amount that became payable as a result of the Tribunal's order (facts of that case led to different result). |
Read by the Court; found distinguishable from the present facts and not inconsistent with Abdul Kareem Hajee; Court noted the case confirmed the earlier case's ratio insofar as factual differences are accounted for. |
| Mohammed Essa Moosa Sait v. Gift-tax Officer, 167 ITR 338 (Kerala HC, Division Bench) |
Dealt with provisions pari materia and endorsed the Abdul Kareem Hajee view, confirming that interim appellate proceedings do not extinguish earlier demand notices which can revive upon finality. |
Relied upon by the Court as reinforcing the Abdul Kareem Hajee principle and applicable by analogy to section 220(2) situations. |
| Income-tax Officer, Central Circle XVIII, Calcutta v. Ghanshyamdas Jatia and others, 105 ITR 693 (Calcutta HC) |
Held that certificate or recovery proceedings started under original assessment remain in abeyance during appeal and will abide by the last order as it attains finality; demand/certificate does not get extinguished. |
Adduced by the Court to support the conclusion that an earlier demand can be treated as suspended and later revived by a final appellate decision, thereby attracting section 220(2). |