“interest under section 234A”

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.

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.

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.

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.

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.

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

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.

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.