| Case ID |
2fe819a1-7316-437c-aaaf-2be91ece54a2 |
| Body |
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| Case Number |
D. B. Income-tax Reference No. 60 of 1995 |
| Decision Date |
May 13, 1996 |
| Hearing Date |
|
| Decision |
The Income-tax Appellate Tribunal, Jaipur Bench, Jaipur, for the assessment years 1985-86 and 1986-87, referred the question of law regarding the legality of allowing interest under section 214 on excess tax deducted at source under section 194-C of the Income Tax Act. The court held that interest is not allowable on the excess amount deducted at source, citing previous cases including CIT v. Hindustan Engineering Co. and Lord Krishna Bank Ltd. v. ITO. The reference was answered in favor of the Revenue and against the assessee, confirming that the tribunal was not justified in allowing the interest. |
| Summary |
In the case of Commissioner of Income Tax vs. Mohta Constructions Co, the Rajasthan High Court addressed the issue of tax deductions at source under the Income Tax Act, 1961. The court examined whether the Income-tax Appellate Tribunal was correct in allowing interest under section 214 for excess tax deducted at source as per section 194-C. The ruling clarified that the provisions of section 214 do not apply to refunds from amounts deducted at source, reinforcing the legal interpretation that excess tax deductions do not warrant interest claims. This judgment is pivotal for tax professionals and businesses to understand the limitations of tax refund claims related to excess deductions. The case references established precedents which guide similar tax-related disputes, making it a significant point of reference for advocates and tax consultants. Understanding the nuances of this ruling is crucial for compliance with tax regulations and for effective financial planning. The case emphasizes the importance of accurate tax deduction practices to avoid unnecessary disputes and promotes awareness of taxpayer rights regarding deductions and refunds. |
| Court |
Rajasthan High Court
|
| Entities Involved |
Income-tax Appellate Tribunal, Jaipur Bench
|
| Judges |
B. R. ARORA,
A. S. GODARA
|
| Lawyers |
Sandeep Bhandawat,
B. C. Mehta
|
| Petitioners |
COMMISSIONER OF Income Tax
|
| Respondents |
MOHTA CONSTRUCTIONS CO
|
| Citations |
1999 SLD 310,
1999 PTD 2181,
(1997) 227 ITR 124
|
| Other Citations |
CIT v. Hindustan Engineering Co. (1995) 215 ITR 527 (Raj.),
Lord Krishna Bank Ltd. v. ITO (1989) 176 ITR 508 (Ker.)
|
| Laws Involved |
Income Tax Act, 1961
|
| Sections |
194,
214
|