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1Fix the driver behind crashes, sound loss and screen glitches2Repair Windows errors before they cause bigger problems3Scan for outdated or missing drivers - takes under a minuteFor cash tax that was actually credited to the Government through a PMT-06 challan, GSTAT Delhi has held that Section 50(1) interest stops on the credit date rather than continuing until the taxpayer files GSTR-3B and the Electronic Cash Ledger is debited. The ruling is fact-sensitive: the amount must have reached the Government account and remained available until the later debit. It does not automatically erase interest where the challan was paid late, the amount was not continuously available, or a different tax period and statutory amendment apply.
What GSTAT Delhi decided
The issue in Laldeo Rajak v Kanthwal Services
Delhi State Bench Division Bench II of the Goods and Services Tax Appellate Tribunal considered Central Tax Appeal APL/79/DEL/2026. The question was whether interest under Section 50(1) should run until the date a delayed GSTR-3B debits the Electronic Cash Ledger, or only until the earlier date on which cash paid through PMT-06 was credited to the Government account.
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The tribunal adopted the earlier date for cash actually received by the Government. Its formulation was whether, “once cash has actually reached the Government’s account through a PMT-06 challan,” interest continues to the later return-filing debit or stops at the credit date. The tribunal concluded that the later debit is not the first point at which that cash became available to the Government.
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The reported order, dated 15 October 2026 according to TaxCorp’s 2026 report, confirmed the order-in-appeal. It dismissed the Department’s appeal and the respondent’s cross-objection. TaxGuru’s 2026 report gives these figures for the case:
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| Item | Amount or description |
|---|---|
| Interest quantified for FY 2017-18 | ₹40,47,151 |
| Amount already paid and credited | ₹15,00,000 |
| Reported remaining interest balance | ₹25,47,151 |
| Penalty | ₹45,829 |
Those amounts belong to that taxpayer’s FY 2017-18 dispute. They are not a standard interest rate, a nationwide average, or a general amount payable by other taxpayers.
Why the deposit date and filing date are different events
What happens after a PMT-06 payment
A taxpayer paying cash tax ordinarily generates a PMT-06 challan and completes the bank payment. After the bank successfully receives the funds, a Challan Identification Number (CIN) is generated. The amount is then reflected in the taxpayer’s Electronic Cash Ledger. The GST Council’s 53rd-meeting agenda describes this trail as money entering the Government account before it is later used through a return-generated ledger debit.
- Challan creation: the taxpayer generates PMT-06 for the amount to be paid.
- Bank receipt: successful receipt by the bank creates the payment record and CIN.
- Government-account credit: the cash reaches the Government account and is reflected in the Electronic Cash Ledger.
- Return filing: filing GSTR-3B uses the available cash balance, causing the accounting debit against the tax liability.
The Delhi tribunal treated step three as the legally relevant payment event for this cash amount. Step four records how the payment is applied in the return; it is not necessarily the date on which the Government first received the money.
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Rule 88B and the earlier administrative position
The 53rd GST Council agenda reproduced Rule 88B’s delayed-return method and recorded the then-existing interpretation that a deposit in the Electronic Cash Ledger before GSTR-3B filing did not itself discharge the tax liability. In the agenda’s words, “Any deposit in the Electronic Cash Ledger prior to the due date of filing of GSTR 3B return does not amount to discharge of tax liability on the part of the registered person.”
The same official material proposed a proviso that would exclude amounts credited by the due date and continuously held until a later debit from the delayed-filing interest calculation. That policy proposal matters because the effective date and wording of any enacted amendment can determine which tax periods are covered; a taxpayer should not assume that a later clarification automatically rewrites every earlier period.
How the ruling affects common filing situations
| Payment and filing pattern | Likely treatment under the Delhi ruling | Important condition |
|---|---|---|
| Cash credited by the applicable due date; GSTR-3B filed later | Interest on that cash amount stops on the Government-account credit date, not the later ledger debit date. | The amount must have remained available continuously until debit. |
| Cash deposited after the due date | Interest can run for the period of late payment up to the date the Government receives the cash. | The deposit-date benefit does not make a late challan timely. |
| Only a ledger entry is shown, with no proof of Government-account credit | The taxpayer may not be able to establish the earlier payment event. | Bank receipt, CIN and credit timestamps become critical. |
| Cash was credited but was not continuously available before return debit | The ruling’s benefit is uncertain and may not apply for the entire interval. | Reconcile credits, debits, reversals and any re-credit in the ledger. |
The ruling does not end the conflict among authorities
GSTAT Delhi’s decision is a significant tribunal ruling, but the legal landscape is not uniform. In RSB Transmissions, the Jharkhand High Court took the contrary view that the liability was discharged only when GSTR-3B was filed and the Electronic Cash Ledger was debited. On that approach, a prior deposit remained merely a deposit.
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The Madras High Court position, summarized in an EY Tax Alert dated 2 February 2024, follows the deposit-date approach. EY quoted the court as stating: “The date when the amount is deposited or credited to the Government will be the actual date of discharge of tax liability.” Under that reasoning, delayed GSTR-3B filing alone does not create interest when the tax was credited within the prescribed time; only amounts deposited late attract interest.
Other decisions described as part of the Gujarat line also need to be read in their own statutory and factual setting. The competing approaches can be compared as follows:
| Authority | Payment event treated as decisive | Practical implication |
|---|---|---|
| GSTAT Delhi, Laldeo Rajak v Kanthwal Services | Government-account credit through PMT-06 for cash actually received | Interest stops at credit, subject to continuous availability and proof. |
| Jharkhand High Court, RSB Transmissions | GSTR-3B filing and Electronic Cash Ledger debit | Prior deposit alone does not discharge the liability. |
| Madras High Court, as summarized by EY on 2 February 2024 | Deposit or credit to the Government | Late filing alone does not create interest on timely credited amounts. |
Because these approaches conflict, an adjudicating officer, appellate authority or court may examine the binding precedent applicable to the taxpayer, the tax period and the precise payment record rather than applying one formula to every case.
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Limits that can change the result
Tax period and amendment date
Identify the return period first. Rule 88B wording, later provisos and any amendment’s effective date can differ from the period under dispute. A clarification proposed in the 53rd Council agenda is not, by itself, proof that every earlier period receives the same treatment.
Whether enforcement proceedings had begun
Check whether proceedings under Section 73 or Section 74 had commenced and what demand, order or appeal is being challenged. A payment-date argument may operate differently in a voluntary correction, a scrutiny response and an appeal against an adjudicated demand.
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Whether the exact amount was credited and stayed available
The ruling concerns cash that actually reached the Government account. A challan that failed, was reversed, was credited for a different amount or was not available when the return debit occurred requires separate reconciliation. Interest relief should be calculated only for the amount and period supported by the records.
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How to document and raise a deposit-date claim
- Collect the PMT-06 challan showing the tax amount, payment date and relevant tax period.
- Preserve the CIN and bank evidence, including the successful-receipt confirmation and bank-credit timestamp.
- Download the Electronic Cash Ledger and mark the credit entry, every intervening debit or reversal, and the debit created when GSTR-3B was filed.
- Record the return timeline: statutory due date, actual filing date and the exact amount applied to the liability.
- Recompute interest under the applicable Rule 88B method, separating any amount paid after the due date from cash credited on time.
- State the legal basis in the reply or appeal: cite the GSTAT Delhi holding, explain the Government-account credit event and address the contrary RSB Transmissions approach if the department relies on it.
- Verify the portal calculation before payment or amendment. The GST portal’s interest calculator and implementation instructions can change, so compare the system result with the documented timeline and obtain professional advice for a disputed demand.
A practical example
Assume a taxpayer’s cash tax is credited through PMT-06 on the statutory due date but GSTR-3B is filed several days later. Under the Delhi ruling, the interest calculation for that credited amount ends on the credit date, provided the balance remains available until the return debit. The filing delay by itself does not extend interest for those days.
If the taxpayer instead pays the challan after the due date, the late interval precedes the Government-account credit. The deposit-date approach does not convert that late payment into a timely one; interest for the late-deposited amount can still be due up to the credit date.
What taxpayers should do now
- Do not rely on the Electronic Cash Ledger balance alone; establish when the Government received the money.
- Keep the PMT-06, CIN, bank-credit evidence, ledger extract and GSTR-3B filing record together.
- Separate amounts credited on time from amounts deposited late.
- Check the tax period, amendment effective date and stage of any Section 73 or 74 proceeding.
- Treat GSTAT Delhi, RSB Transmissions and the Madras/Gujarat authorities as a live conflict until the precedent applicable to the dispute is clear.
There is no published nationwide statistic establishing how many taxpayers will obtain a reduction or how much interest will be saved. The value of the ruling is instead in the payment-event analysis: for qualifying cash, the Government-account credit date can be earlier than the GSTR-3B filing and ledger-debit date, and the documentary trail determines whether that distinction can be proved.
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