The ITAT Chennai held that an income tax return e-verified after filing is deemed filed on the original due date for interest under Section 234A, as long as filed within the extended time.
E-Verification Timing: Return Deemed Filed on Original Date
The Income Tax Appellate Tribunal (ITAT), Chennai, ruled that for the purpose of calculating interest under Section 234A, a return of income is deemed to be filed on the original due date if filed within the extended time and subsequently e-verified, even if e-verification occurs later.
The tribunal quashed a rectification order under Section 154 that imposed interest from the date of e-verification, noting that the statutory requirement under Section 139(1) is satisfied upon filing the return within the extended due date. The obligation of e-verification under Rule 12 of the Income-tax Rules does not alter the filing date for interest computation under Section 234A.
The return is considered filed on the date of submission, not the e-verification date, for the purpose of determining delay and interest liability.
This decision provides relief to taxpayers who file returns before the extended deadline but delay in e-verification. It clarifies that such delay does not attract additional interest under Section 234A, reinforcing procedural fairness. Practitioners should ensure timely filing within extended deadlines, though prompt e-verification remains advisable.
Citations
- Section 139(1), Income Tax Act
- Section 234A, Income Tax Act
- Section 154, Income Tax Act
