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“interest under section 234A”

InterestSection 234ASection 234A1,249 judgments

The decision most relied on for interest under section 234A is CIT v. Anjum M.H. Ghaswala (252 ITR 1), cited in 452 judgments on BharatTax.

Leading authorities on interest under section 234A

CIT v. Anjum M.H. Ghaswala
252 ITR 1 · 2001 · Supreme Court
452
citing judgments

Levy of interest under sections 234A, 234B, and 234C of the Income Tax Act is mandatory. Tax statutes are to be interpreted strictly, allowing no room for purposive interpretation.

Challapalli Sugars Ltd. v. CIT
98 ITR 167 · 1975 · Supreme Court
185
citing judgments

Interest on borrowed capital utilized for acquiring a capital asset is capitalized until business commences. Once business is set up, this interest is deductible under section 36(1)(iii) even if the asset has not yet been put to use, accepting commercial accounting standards in the absence of contrary statutory provisions.

Karanvir Singh Gossal v. CIT
349 ITR 692 · 2012 · Supreme Court
158
citing judgments

The Supreme Court's decision establishes principles or grounds for seeking a waiver of mandatory interest levied under Sections 234A, 234B, and 234C of the Income Tax Act, 1961.

CIT v. Patni Computer Systems Ltd.
215 Taxmann 108 · 2013 · High Court
92
citing judgments

The provision of an extended credit period or non-charging of interest on delayed receivables from associated enterprises constitutes an international transaction under Section 92B(1) and requires separate benchmarking at arm's length, even retrospectively due to the Finance Act, 2012 amendment.

Smt. Renuka Philip v. ITO
409 ITR 567 · 2018 · High Court
85
citing judgments

Revisionary jurisdiction under Section 263 of the Income-tax Act is barred if the issue in question is already pending appeal before the Commissioner (Appeals), as per Explanation 1(c) to Section 263.

DIT v. Mitshubishi Corporation
130 Taxmann.com 276 · 2021 · Supreme Court
70
citing judgments

The Supreme Court's decision in DIT Vs. Mitshubishi Corporation covers the chargeability of interest under section 234B of the Act.

Punjab Stainless Steel Inds v. CIT
324 ITR 396 · 2010 · High Court
66
citing judgments

This case establishes that merely having sufficient interest-free own funds does not automatically prevent interest disallowance on interest-free advances; the assessee must affirmatively prove the business or commercial expediency of such advances.

Dr. Prannoy Roy v. Commissioner of Income-tax
254 ITR 755 · 2002 · High Court
61
citing judgments

Interest under Section 234A cannot be charged when tax has been paid, even if the return of income is filed belatedly, as such interest is compensatory and not penal in nature and only applies if there is a loss caused to the revenue.

Judgments citing interest under section 234A

Seema Singh, Gurgaon vs. DCIT, Central Central-1, Guwahati

Appeal is partly allowed for statistical purposes

ITA 89/GTY/2023[2021-22]Status: DisposedITAT Guwahati16 Oct 2025AY 2021-22

Bench: SHRI MANOMOHAN DAS, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 250Section 56(2)(x)

grounds. 9. That the leamed Deputy Commissioner of Income Tax and CIT (a) has erred both in law and on facts in levying interest under section 234A of the Act. u/s 2348 of the Act, and 234 C of act. 1961 which are not leviable on the facts

Jindal Poly Films Ltd., New Delhi vs. ACIT, New Delhi

ITA 3990/DEL/2016[2006-07]Status: DisposedITAT Delhi16 Oct 2025AY 2006-07

Bench: Shri S. Rifaur Rahman & Ms. Madhumita Royasstt. Yr: 2006-07

Section 132Section 139(5)Section 143Section 14ASection 153ASection 234ASection 263

oriented mutual funds. 3. That the CIT(A) erred on facts and in law in confirming action of the assessing officer in charging interest under section 234A. 234B and 234D of the Act. The appellant craves leave to add, amend, alter or vary from the above grounds of appeal

Naveen Kumar Musinipally, Usa vs. ADIT (Int-Taxn)-1, Hyderabad

In the result, appeal of the Assessee partly

ITA 323/HYD/2024[2016-2017]Status: DisposedITAT Hyderabad15 Oct 2025AY 2016-2017

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: CA, K C DevdasFor Respondent: Sri Posu Babu Alli, Sr. AR
Section 127Section 132Section 142(1)Section 153CSection 2(47)Section 2(47)(v)Section 234A

value of the land as on 01.04.2001. 6. The learned CIT(A) erred in holding that the assessee is liable to interest under section 234A of the Act as it is consequential in nature. 7. The Appellant craves to add, modify or amend the above grounds anytime during the course

Shri Mahaveer Charitable Trust, Allahabad vs. ITO(Exemption), Allahabad

In the result, the appeal of the assessee is partly allowed

ITA 181/ALLD/2024[2013-14]Status: DisposedITAT Allahabad14 Oct 2025AY 2013-14

Bench: Sh. Subhash Malguria & Sh. Nikhil Choudharya.Y. 2013-14 Shri Mahaveer Charitable Trust, Vs Income Tax Officer 46, Rajendra Nagar, Baluaghat, (Exemption), Allahabad Allahabad-211003, U.P. Pan: Aahts9123K (Appellant) (Respondent) Assessee By: Dr. Pawan Jaiswal & Sh. Ajit Kumar, Advocates Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 22.07.2025 Date Of 14.10.2025 Pronouncement: O R D E R Per Nikhil Choudhary, A.M. This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit, Nfac Dated 28.09.2024, Wherein The Ld. Cit(A) Has Dismissed The Appeal Of The Assessee That Was Filed Against The Orders Of The Income Tax Officer (Exemption), Allahabad Dated 30.03.2018. The Grounds Of Appeal Are As Under: - “1. Because The Impugned Order Of The Ld. Cit(A) Dated 28.09.2024 Affirming The Addition Of Rs. 1,97,69,650/- On Account Of Donation Received & Rejection Of The Submissions Of The Appellant That Appeal Proceedings Pending Against The Order Passed Under Section 143(3) Dated 30.03.2016 Are Infructuous Is Absolutely Illegal & Against The Principles Of Law. 2. Because The Hon'Ble Supreme Court In The Case Of Cit V. Alagendran Finance Ltd. [27.07.2007] Had Observed That When An Order Of Assessment Is Reopened, The Previous Assessment Will Be Held To Be Set Aside & The Whole Proceedings Would Start Afresh & In The Case In Hands The Assessment Order Dated 30.03.2016 Has Been Set-Aside By The Then Incumbent Ld. Cit(E); That Is To Say That No Assessment Existed On The Date When Order Dated 28.02.2018 Under Section 263 Of The Act Was Passed By The Then Incumbent Cit(E). 3. Because Section 263 Of The Act Grants Power To The Jurisdictional Commissioner To Direct For Revision Of Orders & Reads As Under (Relevant Statute Quoted):

For Appellant: Dr. Pawan Jaiswal & Sh. Ajit Kumar, AdvocatesFor Respondent: Sh. A.K. Singh, Sr. DR
Section 143(3)Section 263

observed that even though the anonymous donations amounting to Rs. 1,97,69,650/- had been charged to tax under section 115BBC, the interest under section 234A and 234B had not been charged. The ld. Sr. DR pointed out that this order under section

Dimple Rajesh Oswal, Pune vs. Income Tax Officer Ward 5(1), Pune

In the result, the appeal filed by the assessee is allowed

ITA 1506/PUN/2025[2016-17]Status: DisposedITAT Pune14 Oct 2025AY 2016-17

Bench: Shri R. K. Pandaassessment Year : 2016-17

For Appellant: Shri Bharat ShahFor Respondent: Ms. Sailee Dhole, JCIT
Section 143(2)Section 143(3)Section 148Section 148ASection 56(2)(vii)

this respect. 6) The learned assessing officer erred in the facts and circumstances of the case, and as per the law, in levying interest under section 234A, 234B. Just and proper relief be granted to the assessee in this respect. 7) The Appellant prays to be allowed to add, amend

Swaminathan Sukumar, Salem vs. ITO, Ward-1(6), Salem

In the result, appeal filed by the assessee is allowed

ITA 1105/CHNY/2025[2020-21]Status: DisposedITAT Chennai14 Oct 2025AY 2020-21

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunatha

For Appellant: Shri G. Baskar, AdvocateFor Respondent: Ms. Anitha, Addl.CIT
Section 139Section 139(1)Section 140B(3)Section 140B(3)(i)Section 140B(3)(ii)Section 143(1)Section 143(1)(a)Section 234ASection 234F

processing the return under section 143(1), levied additional tax under section 140B(3)(ii) at 50% (instead of 25%) and computed interest under section 234A till 31.10.2022, i.e., the date of filing of the return, instead of the date of tax payment (25.05.2022), resulting in a net demand ... 1105/Chny/2025 (i) Whether the additional income tax under section 140B(3) should be levied at 25% or 50% ? (ii) Whether interest under section 234A should be computed only up to the date of tax payment (25.05.2022) and not up to the date of filing the Updated Return (31.10.2022) ? 7. Assessee

Warner Bros Distributing Inc., United States of America vs. The Assistant Commissioner of Income Tax, Circle International Taxation 4(3)(2), Mumbai

In the result, the appeal by the assessee is partly allowed

ITA 3411/MUM/2023[AY 2020-21]Status: DisposedITAT Mumbai13 Oct 2025

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Deepak Chopra (virtually present)For Respondent: Shri Satya Pal Kumar, CIT (DR)
Section 143(3)Section 144CSection 144C(5)Section 9(1)(vi)

Other Grounds 6. 1. That on the facts and circumstances of the case and in law, the Ld. AO has erred in levying interest under section 234A and section 234B of the Act; and 6. 2. That on the facts and circumstances of the case ... Ground Nos.5.1 and 5.2 raised in assessee's appeal are allowed. 30. Ground no.6.1, raised in assessee's appeal, pertains to levy of interest under section 234A and section 234B of the Act, which are consequential in nature. Therefore, the same needs no separate adjudication. 31. Ground no.6.2, raised

Assistant Commissioner of Income Tax, Kautilya Bhavan, Bkc, Mumbai vs. Tata Education Trust, Mumbai

In the result, Revenue’s appeal is dismissed

ITA 4852/MUM/2024[2013-14]Status: DisposedITAT Mumbai10 Oct 2025AY 2013-14

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w ShriFor Respondent: Shri Ritesh Mishra, CIT DR
Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

facts and under the circumstances of the case and in law, the Ld. CIT(A) erred in upholding levy of interest under section 234A, 234B and 234C of the Act on the additions not envisaged by the Appellant.” 26. Ground No.1 is identical to Ground

Tata Education Trust, Mumbai vs. Assistant Commissioner of Income Tax-17(3), Mumbai

In the result, Revenue's appeal is dismissed

ITA 4835/MUM/2024[2017-18]Status: DisposedITAT Mumbai10 Oct 2025AY 2017-18

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

facts and under the circumstances of the case and in law, the Ld. CIT(A) erred in upholding levy of interest under section 234A, 234B and 234C of the Act on the additions not envisaged by the Appellant." 26. Ground No.1 is identical to Ground

Tata Education Trust, Mumbai vs. Assistant Commissiioner of Income Tax Circle 17(3), Mumbai

In the result, Revenue’s appeal is dismissed

ITA 4727/MUM/2024[2016-17]Status: DisposedITAT Mumbai10 Oct 2025AY 2016-17

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w ShriFor Respondent: Shri Ritesh Mishra, CIT DR
Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

facts and under the circumstances of the case and in law, the Ld. CIT(A) erred in upholding levy of interest under section 234A, 234B and 234C of the Act on the additions not envisaged by the Appellant.” 26. Ground No.1 is identical to Ground

Tata Education Trust, Mumbai vs. Assistant Commissioner of Income Tax Circle -17(3), Mumbai

In the result, Revenue's appeal is dismissed

ITA 4496/MUM/2024[2016-17]Status: DisposedITAT Mumbai10 Oct 2025AY 2016-17

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w ShriFor Respondent: Shri Ritesh Mishra, CIT DR
Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

facts and under the circumstances of the case and in law, the Ld. CIT(A) erred in upholding levy of interest under section 234A, 234B and 234C of the Act on the additions not envisaged by the Appellant." 26. Ground No.1 is identical to Ground

Assistant Commissioner of Income Tax- 26(1), Mumbai vs. Tata Education Trust, Mumbai

In the result, Revenue's appeal is dismissed

ITA 4419/MUM/2024[2014-15]Status: DisposedITAT Mumbai10 Oct 2025AY 2014-15

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

facts and under the circumstances of the case and in law, the Ld. CIT(A) erred in upholding levy of interest under section 234A, 234B and 234C of the Act on the additions not envisaged by the Appellant." 26. Ground No.1 is identical to Ground

Tata Education Trust, Mumbai vs. Deputy Commissioner of Income Tax (Exeption) -Circle 2(1), Mumbai

In the result, Revenue's appeal is dismissed

ITA 4283/MUM/2024[2013-14]Status: DisposedITAT Mumbai10 Oct 2025AY 2013-14

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

facts and under the circumstances of the case and in law, the Ld. CIT(A) erred in upholding levy of interest under section 234A, 234B and 234C of the Act on the additions not envisaged by the Appellant." 26. Ground No.1 is identical to Ground

Tata Education Trust, Mumbai vs. Deputy Commissioner of Income Tax (Exemption)-Circle 2(1), Mumbai

In the result, Revenue’s appeal is dismissed

ITA 4282/MUM/2024[2014-15]Status: DisposedITAT Mumbai10 Oct 2025AY 2014-15

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w ShriFor Respondent: Shri Ritesh Mishra, CIT DR
Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

facts and under the circumstances of the case and in law, the Ld. CIT(A) erred in upholding levy of interest under section 234A, 234B and 234C of the Act on the additions not envisaged by the Appellant.” 26. Ground No.1 is identical to Ground

Tata Education Trust, Mumbai vs. ACIT-17(3), Mumbai

In the result, Revenue's appeal is dismissed

ITA 4156/MUM/2024[2015-16]Status: DisposedITAT Mumbai10 Oct 2025AY 2015-16

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w Shri Sukhsagar & Shri Atul SuraiyaFor Respondent: Shri Ritesh Mishra, CIT DR
Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

facts and under the circumstances of the case and in law, the Ld. CIT(A) erred in upholding levy of interest under section 234A, 234B and 234C of the Act on the additions not envisaged by the Appellant." 26. Ground No.1 is identical to Ground

Atos Information Technologies Hk Limited, Mumbai vs. Deputy Commissioner of Income Tax (Int Tax)-1(1)(2), Mumbai

In the result, appeal of the assessee is allowed

ITA 4708/MUM/2023[2021-22]Status: DisposedITAT Mumbai10 Oct 2025AY 2021-22

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

For Appellant: Ms. Chandani Shah a/w Ms. Tejal Saraf &For Respondent: Shri Satya Pal Kumar - CIT D/R
Section 143(2)Section 143(3)Section 144C(13)Section 234ASection 234BSection 270ASection 9

Kong DTAA. 6. On the facts and in the circumstances of the case and in law, the Learned AO has erred in levying interest under section 234A of the Act amounting to Rs. 4,08,932/-. The Appellant humbly prays that the Learned AO be directed to delete interest under

Pawan Kumar Sharma, New Delhi vs. Assistant Director of Income Tax, Banglore

In the result, appeal of the assessee in ITA No

ITA 2509/DEL/2025[2020-21]Status: DisposedITAT Delhi10 Oct 2025AY 2020-21

Bench: Shri Yogesh Kumar Us & Shri Naveen Chandra

For Appellant: Shri Sumit Lalchandani, AdvFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 139(1)Section 143(1)Section 234ASection 36(1)Section 36(1)(va)Section 37

facts and circumstances of the case and in law, the CPC as well as Ld. CIT(A) have erred in charging interest under Section 234A, 234B and 234C of the Act. The charging of interest is illegal and excessive and has been wrongly worked out. It cannot be justified

Padmanaban Sukhumaran, Bangalore vs. ACIT, Circle-5(3)(1), Bangalore

In the result, the appeal filed by the assessee towards the interest claimed u/s

ITA 950/BANG/2025[2017-18]Status: DisposedITAT Bangalore09 Oct 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri Ravishankar, AdvocateFor Respondent: Shri Subramanian S, JCIT-DR
Section 234ASection 24Section 250

that "consent does not confer Jurisdiction" on the facts and circumstances of the case. 5. The appellant denies the liability to pay interest under section 234A, 234B and 234C of the Act in view of the fact that there is no liability to additional tax as determined by the learned

Jogpl Pvt Ltd, Uttar Pradesh vs. DCIT Circle-13(1) Delhi, Delhi

In the result, the appeal of the assessee is partly allowed for 14

ITA 1718/DEL/2022[2017-18]Status: DisposedITAT Delhi08 Oct 2025AY 2017-18

Bench: Shri C. N. Prasad & Shri M. Balaganeshjogpl Pvt. Ltd, Vs. Dcit, Plot No. 15, Knowledge Circle-13(1), Park-2, Greater Noida, Delhi Up 2011306 (Appellant) (Respondent) Pan: Aaace0169K Assessee By : Shri M. K. Gupta, Adv Revenue By: Shri S. K. Jadav, Cit Dr Date Of Hearing 17/07/2025 Date Of Pronouncement 08/10/2025

For Appellant: Shri M. K. Gupta, AdvFor Respondent: Shri S. K. jadav, CIT DR
Section 143(3)Section 144C(5)Section 92C

raised by the assessee is challenging the interest 13. under section 234A, 234B, 234C and 234D of the Act. With regard to interest under section 234A of the Act, the learned AO is directed to verify whether the return has been filed by the assessee within the due date prescribed ... under the Act read with extension given by the CBDT from time to time for the year under consideration. Accordingly, the interest under section 234A of the Act is to be decided. The chargeability of interest under section 234B and 234D of the Act is consequential in nature. With regard

Bidyut Prakas Bhattacharya, Kolkata vs. I.T.O., Ward - 52(1), Kolkata

In the result, the appeal filed by the assessee is allowed

ITA 2016/KOL/2024[2018-2019]Status: DisposedITAT Kolkata07 Oct 2025AY 2018-2019

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 139(1)Section 143(1)Section 154Section 234ASection 234BSection 234CSection 250Section 90

well as on law, the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC) has erred in confirming the levy of interest under section 234A amounting to Rs. 38,394. 4. That on facts as well as on law, the Learned Commissioner of Income Tax (Appeals), National Faceless ... benefit towards the claim for foreign tax paid in Kenya against his salary income in determining his final tax liability. 2. Impugned levying interest under section 234A amounting to Rs. 38,394. The Learned Deputy Director of Income Tax, CPC, Bengaluru, has passed the order under section 154 in ignoring