← All Phrases

“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

Shanmugasundaram Venkatachalapathy, Tirunelveli, Tamilnadu vs. Income Tax Officer, Ward 4, Tirunelveli

In the result, grounds of appeal raised

ITA 2056/CHNY/2024[2017-18]Status: HeardITAT Chennai26 Sept 2025AY 2017-18

Bench: Shri Ss Viswanethra Ravi & Shri Ratnesh Nandan Sahayshri Shanmugasundaram I.T.O., Venkatachalapathy, Vs. Ward-4, C/O-Durv & Associates Llp, No. Tirunelveli. 10/80, Avm Avenue 3Rd Street, Virugambakkam, Chennai-600092 (Tamil Nadu) Pan No. Acapv 3414 B Appellant/ Assessee Respondent/ Revenue

Section 115BSection 143(2)Section 143(3)Section 147Section 234ASection 250Section 56(2)(vii)Section 69

without providing an opportunity of being heard by way of a virtual hearing/ video conference. Ground No. 5 Levy of interest under section 234A, 234B, 234C and 234D of the Act 11. The learned AO has erred in levying interest under section 234A, 234B, 234C and 234D

Late Shri Mahabir Prasad(Legal Heir Ms. Parul Kansaria), Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bengaluru

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

ITA 412/BANG/2024[2020-21]Status: DisposedITAT Bangalore26 Sept 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

Section 132Section 143(3)Section 144Section 153CSection 153D

decision of the honourable Supreme Court in case of coronary Singh 349 ITR 692, the appellant denies himself liable to be charged to interest under section 234A, 234B and 234C of the income tax act on the facts and circumstances of the case. The appellant contends that the levy ... interest under section 234A, 234B and 234C of the act is also bad in law as the period, rate, quantum, and method of calculation adopted by the learned AO on which interest has levied are not discernible and are wrong on the facts of the case. 49. The learned Authorised

Late Shri Mahabir Prasad(Legal Heir Ms. Parul Kansaria), Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle - 1(3), Bengaluru

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

ITA 411/BANG/2024[2019-20]Status: DisposedITAT Bangalore26 Sept 2025AY 2019-20

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

Section 132Section 143(3)Section 144Section 153CSection 153D

decision of the honourable Supreme Court in case of coronary Singh 349 ITR 692, the appellant denies himself liable to be charged to interest under section 234A, 234B and 234C of the income tax act on the facts and circumstances of the case. The appellant contends that the levy ... interest under section 234A, 234B and 234C of the act is also bad in law as the period, rate, quantum, and method of calculation adopted by the learned AO on which interest has levied are not discernible and are wrong on the facts of the case. 49. The learned Authorised

Late Shri Mahabir Prasad(Legal Heir Ms. Parul Kansaria), Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bengaluru

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

ITA 410/BANG/2024[2018-19]Status: DisposedITAT Bangalore26 Sept 2025AY 2018-19

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

Section 132Section 143(3)Section 144Section 153CSection 153D

decision of the honourable Supreme Court in case of coronary Singh 349 ITR 692, the appellant denies himself liable to be charged to interest under section 234A, 234B and 234C of the income tax act on the facts and circumstances of the case. The appellant contends that the levy ... interest under section 234A, 234B and 234C of the act is also bad in law as the period, rate, quantum, and method of calculation adopted by the learned AO on which interest has levied are not discernible and are wrong on the facts of the case. 49. The learned Authorised

DCIT, Central Circle-1(3), Bengaluru vs. Late Shri Mahabir Prasad (Legal Heir Ms. Parul Kansaria), Bengaluru

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

ITA 170/BANG/2024[2018-19]Status: DisposedITAT Bangalore26 Sept 2025AY 2018-19

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

Section 132Section 143(3)Section 144Section 153CSection 153D

decision of the honourable Supreme Court in case of coronary Singh 349 ITR 692, the appellant denies himself liable to be charged to interest under section 234A, 234B and 234C of the income tax act on the facts and circumstances of the case. The appellant contends that the levy ... interest under section 234A, 234B and 234C of the act is also bad in law as the period, rate, quantum, and method of calculation adopted by the learned AO on which interest has levied are not discernible and are wrong on the facts of the case. 49. The learned Authorised

DCIT, Central Circle-1(3), Baengaluru vs. Late Shri Mahabir Prasad(Legal Heir Ms. Parul Kansaria), Bengaluru

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

ITA 169/BANG/2024[2017-18]Status: DisposedITAT Bangalore26 Sept 2025AY 2017-18

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

Section 132Section 143(3)Section 144Section 153CSection 153D

decision of the honourable Supreme Court in case of coronary Singh 349 ITR 692, the appellant denies himself liable to be charged to interest under section 234A, 234B and 234C of the income tax act on the facts and circumstances of the case. The appellant contends that the levy ... interest under section 234A, 234B and 234C of the act is also bad in law as the period, rate, quantum, and method of calculation adopted by the learned AO on which interest has levied are not discernible and are wrong on the facts of the case. 49. The learned Authorised

Jakhad Enterprise LLP, Mumbai vs. Income Tax Officer 41(1)(3), Mumbai

In the result, appeal of the assessee is allowed for statistical purposes

ITA 4985/MUM/2025[2023-24]Status: DisposedITAT Mumbai26 Sept 2025AY 2023-24

Bench: MS. KAVITHA RAJAGOPAL (Judicial Member), SHRI OMKARESHWAR CHIDARA (Accountant Member)

Section 143(1)Section 143(3)Section 154Section 194Section 194QSection 234ASection 250Section 270ASection 274Section 40

actual returned income there not considering the rectification order u/s 154 dated 27/5/2024 3) The Ld CIT(A) erred in charging Interest under section 234A,234B and 234C of the Income Tax Act 1961 4) The Ld CIT erred in initiating penalty proceeding under section 270A r.w.s 270A

Mahindra and Mahindra Limited (As Sucessor to Mahindra Two Wheelers Limited Which in Turn Is Sucessor to Mahindra Trucks and Buses Limited), Mumbai vs. Deputy Commissioner of Income Tax Circle 2(2)(1), Mumbai

ITA 4964/MUM/2025[2018-19]Status: DisposedITAT Mumbai25 Sept 2025AY 2018-19
Section 115JSection 143(1)Section 143(3)Section 234ASection 234CSection 250Section 254(1)Section 270ASection 28Section 37

facts and in the circumstances of the case and in law, the learned CIT(A) erred in upholding interest under section 234A and not adjudicating ground on interest levied under sections 234C of the Act. b. On the facts and in the circumstances of the case ... learned the AO be directed to delete the interest charged or appropriately reduce interest under sections 234A, 234B of the Act, as per law, and interest under section 234C be restricted to amount as per Income tax return filed. 4. Initiation of penalty proceeding under section 270A

Sushee Infra & Mining Limited, Hyderabad vs. ACIT., Central Circle-2(2), Hyderabad

In the result, appeal of the Assessee is partly

ITA 1390/HYD/2024[2021-22]Status: DisposedITAT Hyderabad24 Sept 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: CA Abhiroop BhargavFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 143(3)Section 144C(5)Section 801ASection 801A(10)Section 92BSection 92C(3)Section 92D

That on the facts and circumstances of the case, the Ld. AO erred in the levy of the interest under Section 234A and 234B of the Act . The Appellant craves leave to add, amend, alter, vary and/or withdraw any or all the above grounds of appeal. Each of the Grounds

Dilipkumar Phoolchand Jain, Mumbai vs. DCIT, Circle 20(1), Mumbai

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 3373/MUM/2025[2020-21]Status: DisposedITAT Mumbai24 Sept 2025AY 2020-21

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2020-21 Dilipkumar Phoolchand Jain, Dcit, Circle-20(1), A/1901-1902, Piramal Chambers, Vardhman Heights, Vs. Dr.Ss Rao Marg, Tb Kadam Marg, Parel, Byculla (East), Mumbai-400012. Mumbai-400027. Pan : Aarpj1996K (Appellant) (Respondent) For Assessee : Mr. Dipesh Ruparelia (Virtually Present) For Revenue : Shri Annavaram Kosuri, Sr.Dr Date Of Hearing : 22-09-2025 Date Of Pronouncement : 24-09-2025 O R D E R Per Vikram Singh Yadav, A.M :

For Appellant: Mr. Dipesh RupareliaFor Respondent: Shri Annavaram Kosuri, Sr.DR
Section 143(3)Section 234ASection 234BSection 270ASection 272A(1)Section 274Section 37(1)Section 57

house property as closing stock; 3 12. Erred in upholding the order of the learned AG wherein, the learned AO has levied interest under Section 234A and Section 234B of the Act; and 13. Erred in upholding the order of the learned AO wherein, the learned AO has initiated penalty

Innovative Textiles Limited, Delhi vs. DCIT, Circle-10(1), New Delhi

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

ITA 1160/DEL/2022[2017-18]Status: DisposedITAT Delhi24 Sept 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Innovative Textiles Limited, Vs. Dcit, Circle 10(1), 81, Vighyan Vihar, New Delhi. Delhi – 110 092. (Pan : Aaaci0473J) (Appellant) (Respondent) Assessee By : Shri Gautam Jain, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 05.08.2025 Date Of Order : 24.09.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against Assessment Order Dated 26.03.2022 Passed By The Income Tax Department/National Faceless Assessment Centre, Delhi U/S 143(3) Read With Section 144C(13)/144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2017-18 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act Raising Following Grounds Of Appeal :- “1. That The Orders Of The Learned Lower Tax Authorities Is/Are Contrary To The Law & Facts Of The Case.

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Shri S.K. Jadhav, CIT DR
Section 115JSection 143(3)Section 144BSection 144C(13)Section 144C(5)Section 234ASection 270A

lower tax authorities had contrary to law and facts of the case, without any basis and merely on surmises and conjectures, charged interest under section 234A, 234B, 234C & 234D of the Income - tax Act, 1961 that the lower tax authorities had contrary to law and facts of the case, without ... book profits under section 115JB of the Income - tax Act, 1961; g. That the lower tax authorities be directed not to charge interest under section 234A, 234B, 234C & 234 D of the Income - tax Act, 1961; h. That the lower tax authorities be directed to drop penalty proceedings under section

Nilesh Shirish Mehta, Mumbai vs. Income Tax Officer - Ward 42(1)(3), Mumbai

In the result, appeal of the assessee is allowed

ITA 4807/MUM/2025[2015-16]Status: DisposedITAT Mumbai22 Sept 2025AY 2015-16

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

For Appellant: Shri Suchek Anchaliya, A/RFor Respondent: Shri Leyaqat Ali Aafaqui, Sr. D/R
Section 143(2)Section 147Section 148Section 148ASection 234ASection 250Section 68Section 69C

relied upon in the assessment order. 7. The learned CIT(A) erred in not granting appropriate relief in respect of incorrect computation of interest under section 234A. 8. The Appellant craves leave to add, amend, alter, DLEETE, OR withdraw any of the above grounds of appeal.” 3. Briefly stated

Isat Africa Limited Fzc, United Arab Emirates vs. Deputy Commissioner of Income Tax, Mumbai

In the result, the final assessment order passed by AO is set aside and the appeal of the assessee is accordingly allowed in above terms

ITA 832/MUM/2024[2018-19]Status: DisposedITAT Mumbai22 Sept 2025AY 2018-19

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhanisat Africa Limited Fzc Vs. The Deputy Commissioner Office No. 5 Pre-Fab, C Phase Ii, Of Income Tax Fujairah Free Zone Fujairah, Dubai, International Tax Circle- United Arab Emirates, Dubai - 2(2)(2) 999999 Mumbai, Maharashtra. Pan – Aagci8661Q (Appellant) (Respondent)

Section 143(3)Section 144C(5)Section 148Section 148ASection 195Section 201Section 9(1)Section 9(1)(vi)

treaty. 3. That on the facts and circumstances of the case and in law, the Ld. AO has erred in levying interest under section 234A, 234B and 234C of the Act. 4. That on the facts and circumstances of the case and in law, the Ld. AO has erred

M/S Rpj Minerals Pvt. Ltd, Maihar vs. Income Tax Officer, Ward -1, Satna

ITA 86/JAB/2022[2017-18]Status: DisposedITAT Jabalpur19 Sept 2025AY 2017-18

Bench: Sh. Kul Bharat & Sh. Nikhil Choudhary

For Appellant: NoneFor Respondent: Sh. Shrawan Kumar Meena, CIT DR
Section 143(3)Section 234ASection 43B

assessment years. 7. The assessee denies liabilities to pay interest u/s 234A, 234B and 234C of I.T. Act 1961, Without prejudice, levy of interest under section 234A, 234B and 234C of I.T. Act 1961 is unjustified, unwarranted and excessive. 8. Any other ground that shall be prayed at the time

Income Tax Officer Ward-1 vs. M/S Rpj Minerals Private Ltd., Satna

ITA 154/JAB/2016[2012-13]Status: DisposedITAT Jabalpur19 Sept 2025AY 2012-13

Bench: Sh. Kul Bharat & Sh. Nikhil Choudhary

For Appellant: NoneFor Respondent: Sh. Shrawan Kumar Meena, CIT DR
Section 143(3)Section 234ASection 43B

assessment years. 7. The assessee denies liabilities to pay interest u/s 234A, 234B and 234C of I.T. Act 1961, Without prejudice, levy of interest under section 234A, 234B and 234C of I.T. Act 1961 is unjustified, unwarranted and excessive. 8. Any other ground that shall be prayed at the time

DCIT, CC-7(2), Mumbai vs. M/S. Patanjali Foods Ltd., ( Formerly Known As Ruchi Soya Industries Ltd, Mumbai

In the result the appeal filed by the revenue stands dismissed

ITA 1174/MUM/2023[2011-12]Status: DisposedITAT Mumbai17 Sept 2025AY 2011-12

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 132Section 143(3)Section 153ASection 250Section 37(1)

consideration. 1.8 That on the facts and in the circumstances of the case, the Ld. CIT(A) is unjustified in confirming the excessive interest under section 234A, 234B & 234C of the Act charged by the Ld. Ld.AO. 1.9 That the appellant craves leave, to add, to amend, modify, rescind, supplement

DCIT, CC-7(2), Mumbai vs. M/S. Patanjali Foods Ltd., ( Formerly Known As Ruchi Soya Industries Ltd, Mumbai

In the result the appeal filed by the revenue stands dismissed

ITA 1173/MUM/2023[2011-12]Status: DisposedITAT Mumbai17 Sept 2025AY 2011-12

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 132Section 143(3)Section 153ASection 250Section 37(1)

consideration. 1.8 That on the facts and in the circumstances of the case, the Ld. CIT(A) is unjustified in confirming the excessive interest under section 234A, 234B & 234C of the Act charged by the Ld. Ld.AO. 1.9 That the appellant craves leave, to add, to amend, modify, rescind, supplement

Ust Global Technology Services (India) Private Limited, Kochi vs. DCIT, Corporate Circle 2(1), Kochi

In the result, appeal filed by the assessee stands partly allowed

ITA 1071/COCH/2024[2021-22]Status: DisposedITAT Cochin08 Sept 2025AY 2021-22

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary

For Appellant: Respondent byFor Respondent: Shri Rajakannam, Advocate
Section 143Section 92C

such as agreement, terms, etc. 10 11 S.A.No. 66/Coch/2025 & ITA No. 1071/Coch/2024 (UST Global Technology Services (I) P. Ltd. Consequential levy of interest under Section 234A and 2348 of the Act 10.1 On the facts and in the circumstances of the case and in law, the learned AO has erred ... computing interest under section 234A and 234B of the Act. Initiation of penalty proceedings 11.1 The Appellant submits that based on the facts and circumstances of the case, there was no basis for the Ld. AO to initiate proceedings under section 270A and 271AA of the Act.” At the outset

Shri. Bishmit Singh Chawla, Mumbai vs. Income Tax Officer, Ward 41(4)(1), Mumbai

ITA 4238/MUM/2025[2017-18]Status: DisposedITAT Mumbai29 Aug 2025AY 2017-18

Bench: Shri Narender Kumar Choudhry (Jm) & Shri Omkareshwar Chidara (Am) Bishmit Singh Chawla Ito Ward 41(4)(1) Coregaon Wine Shop No. Ii Room No. 603 Hanuman Tekdi, Opp. Vs. Kautilya Bhavan Western Express Highway Bandra Kurla Goregaon East Complex, Bandra-E Mumbai-400 063. Mumbai-400 051. Pan : Afapc7509P Appellant Respondent

For Appellant: Shri Leyaqat Ali AafaquiFor Respondent: Shri Vimal Punmiya
Section 11Section 115BSection 144Section 147Section 148Section 148ASection 234ASection 270ASection 271ASection 69A

opportunity of being heard, which is against the principal of natural justice 7. The Ld NFAC/CIT(A) erred in upholding charging the interest under section 234A 234B 234C and 234D of the Income Tax Act 1961 8. The Ld NFAC/CIT(A) erred in upholding initiation of penalty proceeding under section

Garware Fulflex India Pvt Ltd, Mumbai vs. DCIT, Circle 1(1)(1), Mumbai

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

ITA 6751/MUM/2024[2021-22]Status: DisposedITAT Mumbai28 Aug 2025AY 2021-22

Bench: Smt. Beena Pillai () & Shri Om Prakash Kant ()

Section 143(3)Section 144C(13)Section 153

prepaid taxes corresponding to the transferor companies pursuant to amalgamation with the Appellant. 11. Proposed initiation of penalty proceedings and charge of Interest under section 234A, 234C, and Section 270A of the Act on account of overall adjustment Erred by proposing to initiate the penalty proceedings against the Appellant