CHAPTER XVII - COLLECTION AND RECOVERY OF TAX | D.—COLLECTION AND RECOVERY
CHAPTER XVII - COLLECTION AND RECOVERY OF TAX | D.—COLLECTION AND RECOVERY
Section 229 — Recovery of Penalties, Fine, Interest and Other Sums
Case Laws & Commentary — Income-tax Act, 1961 (as amended by the Finance Act, 2026) — bharattax.co Treatise
Status: Live; extends the entire recovery machinery of Chapter XVII to sums other than tax — interest, fine, penalty and any other sum payable under the Act.
Finance Act, 2026: No amendment by the Finance Act, 2026.
Mechanism: Any sum by way of interest, fine, penalty or any other sum payable under the Act → recoverable in the same manner as arrears of tax under this Chapter (certificate, other modes, etc.).
Litigation profile: Lightly litigated; a deeming/extension provision that ensures non-tax dues ride the same recovery rails.
A. COMMENTARY
An extension provision
Section 229 prevents any argument that the recovery code is limited to 'tax' strictly so called. It declares that interest, fine, penalty and any other sum payable under the Act are recoverable in the manner provided in Chapter XVII for arrears of tax. Thus a penalty under section 221 or 270A, interest under section 220(2) or 234A/B/C, and similar dues can all be carried into a section 222 certificate and recovered through the Second Schedule and the 'other modes' of section 226.
Litigation note
Disputes are usually about the underlying liability (the penalty or interest itself) rather than about section 229, which merely supplies the recovery route. The candour rule is applied; the cognate authorities are those governing the particular levy being recovered.
B. STATUTORY TEXT (verbatim)
Reproduced from the Income-tax Act, 1961 as amended up to the Finance Act, 2025; the Finance Act, 2026 makes no amendment to this section. Editorial '[Omitted...]' notes are those of the Legislature.
Recovery of penalties, fine, interest and other sums.
229. Any sum imposed by way of interest, fine, penalty, or any other sum payable under the provisions of this Act, shall be recoverable in the manner provided in this Chapter for the recovery of arrears of tax.
Position Section 229 is an extension provision; litigation concerns the underlying penalty/interest, not section 229 itself. Recovery of such sums follows the section 222 / section 226 machinery.
Use State the candour position; cite the authority on the underlying levy where relevant.
CHAPTER XVII - COLLECTION AND RECOVERY OF TAX | D.—COLLECTION AND RECOVERY
Section 229 — Recovery of Penalties, Fine, Interest and Other Sums
Case Laws & Commentary — Income-tax Act, 1961 (as amended by the Finance Act, 2026) — bharattax.co Treatise
Status: Live; extends the entire recovery machinery of Chapter XVII to sums other than tax — interest, fine, penalty and any other sum payable under the Act.
Finance Act, 2026: No amendment by the Finance Act, 2026.
Mechanism: Any sum by way of interest, fine, penalty or any other sum payable under the Act → recoverable in the same manner as arrears of tax under this Chapter (certificate, other modes, etc.).
Litigation profile: Lightly litigated; a deeming/extension provision that ensures non-tax dues ride the same recovery rails.
A. COMMENTARY
An extension provision
Section 229 prevents any argument that the recovery code is limited to 'tax' strictly so called. It declares that interest, fine, penalty and any other sum payable under the Act are recoverable in the manner provided in Chapter XVII for arrears of tax. Thus a penalty under section 221 or 270A, interest under section 220(2) or 234A/B/C, and similar dues can all be carried into a section 222 certificate and recovered through the Second Schedule and the 'other modes' of section 226.
Litigation note
Disputes are usually about the underlying liability (the penalty or interest itself) rather than about section 229, which merely supplies the recovery route. The candour rule is applied; the cognate authorities are those governing the particular levy being recovered.
B. STATUTORY TEXT (verbatim)
Reproduced from the Income-tax Act, 1961 as amended up to the Finance Act, 2025; the Finance Act, 2026 makes no amendment to this section. Editorial '[Omitted...]' notes are those of the Legislature.
Recovery of penalties, fine, interest and other sums.
229. Any sum imposed by way of interest, fine, penalty, or any other sum payable under the provisions of this Act, shall be recoverable in the manner provided in this Chapter for the recovery of arrears of tax.
C. AUTHORITIES
Machinery/extension provision; candour rule applied.
1. Candour note
No significant section-specific authority
Position Section 229 is an extension provision; litigation concerns the underlying penalty/interest, not section 229 itself. Recovery of such sums follows the section 222 / section 226 machinery.
Use State the candour position; cite the authority on the underlying levy where relevant.