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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

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

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

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

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

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

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

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

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

Ishares Core Msci Total International Stock Etf (As A Successor to Ishares Core Total International Stock Mauritius Co ), Mumbai vs. Deputy Commissioner of Income Tax (International Taxation)-2(2)(2), Mumbai

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

ITA 2151/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

appeal are allowed for statistical purposes. 17. The issue arising in ground no.7, raised in assessee’s appeal, pertains to the levy of interest under section 234A, 234B, 234C and 234D of the Act, which is consequential in nature. Therefore, the same needs no separate adjudication. 18. The issue arising

Ishares Msci Emerging Markets Etf (As A Successor to Ishares Emerging Markets Index Mauritius Co ), Mumbai vs. Deputy Commissioner of Income Tax (International Taxation)-2(2)(2), Mumbai

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

ITA 2150/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

appeal are allowed for statistical purposes. 17. The issue arising in ground no.7, raised in assessee's appeal, pertains to the levy of interest under section 234A, 234B, 234C and 234D of the Act, which is consequential in nature. Therefore, the same needs no separate adjudication. 18. The issue arising

Ishares India 50 Etf (As A Successor to Ishares India Mauritius Co ), Mumbai vs. Deputy Commissioner of Income Tax (International Taxation)-2(2)(2), Mumbai

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

ITA 2149/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

appeal are allowed for statistical purposes. 17. The issue arising in ground no.7, raised in assessee's appeal, pertains to the levy of interest under section 234A, 234B, 234C and 234D of the Act, which is consequential in nature. Therefore, the same needs no separate adjudication. 18. The issue arising

Ishares Msci Em Ucits Etf Usd Dist, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation)-2(2)(2), Mumbai

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

ITA 2148/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

appeal are allowed for statistical purposes. 17. The issue arising in ground no.7, raised in assessee’s appeal, pertains to the levy of interest under section 234A, 234B, 234C and 234D of the Act, which is consequential in nature. Therefore, the same needs no separate adjudication. 18. The issue arising

Ishares Msci India Ucits Etf, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation )-2(2)(2), Mumbai

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

ITA 2147/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

appeal are allowed for statistical purposes. 17. The issue arising in ground no.7, raised in assessee’s appeal, pertains to the levy of interest under section 234A, 234B, 234C and 234D of the Act, which is consequential in nature. Therefore, the same needs no separate adjudication. 18. The issue arising

Schwab Emerging Markets Equity Etf, Mumbai vs. Deputy Commissioner of Income Tax International Taxation -4(2)(1), Mumbai

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

ITA 2134/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

appeal are allowed for statistical purposes. 17. The issue arising in ground no.7, raised in assessee's appeal, pertains to the levy of interest under section 234A, 234B, 234C and 234D of the Act, which is consequential in nature. Therefore, the same needs no separate adjudication. 18. The issue arising

Ishares Core Msci Emerging Markets Etf (As A Sucessor to Ishares Core Emerging Markets Mauritius Company), Mumbai vs. Deputy Commissioner of Income Tax (International Taxation) 2(2)(2), Mumbai

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

ITA 2085/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

appeal are allowed for statistical purposes. 17. The issue arising in ground no.7, raised in assessee's appeal, pertains to the levy of interest under section 234A, 234B, 234C and 234D of the Act, which is consequential in nature. Therefore, the same needs no separate adjudication. 18. The issue arising

Irm Private Limited, Ahmedabad vs. The DCIT, Circle-2(1)(1), Ahmedabad

In the result the appeal filed by assessee is partly allowed for statistical purposes

ITA 1590/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad10 Jun 2025AY 2011-12

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No. 1590/Ahd/2024 िनधा"रण वष" /Assessment Year : 2011-12 Irm Private Limited, The Deputy Commissioner Irm House, बनाम/ Of Income Tax, V/S. Off. C.G Raod, Circle 2(1)(1), Navrangpura, Ahmedabad. Ahmedabad-380009. "थायी लेखा सं./Pan: Aaaci3678M अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Bandish Soparkar, Ar Revenue By : Shri Abhijit, Sr-Dr

For Appellant: Shri Bandish Soparkar, ARFor Respondent: Shri Abhijit, SR-DR

Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 144Section 147Section 148Section 14ASection 194HSection 194J

including hearing notices dated 25.12.2020, 09.12.2022, 13.04.2023, and up to 19.07.2024, but no valid explanation or supporting evidence was furnished. The levy of interest under sections 234A to 234D was treated as consequential and upheld. The initiation of penalty proceedings under section 271(1)(c) was held ... circumstances of the case and in law, the NFAC erred in confirming the action of the Ld. AO in levying interest under section 234A, 234B, 234C, and 234D of the IT Act. 10. On the facts and in the circumstances of the case and in law, the NFAC erred

Kishore Rambilas Khandelwal, Gulbarga vs. Income Tax Officer, Ward-1, Yadgir

The appeal of the assessee is allowed for statistical purposes

ITA 36/BANG/2025[2015-16]Status: DisposedITAT Bangalore10 Jun 2025AY 2015-16

Bench: Shri Prashant Maharishiassessment Year : 2015-16

For Appellant: Shri S.V. Ravishankar, AdvocateFor Respondent: Shri Ganesh R. Ghale, Standing Counsel for Revenue

Section 144Section 147Section 148Section 151Section 234ASection 250

below the taxable limits for the year, on the facts and circumstances of the case. 7. 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

Sameer Shrikant Pise, Pune vs. DCIT Circle 12, Pune

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

ITA 1078/PUN/2025[2017-18]Status: DisposedITAT Pune06 Jun 2025AY 2017-18

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri V. Balaji, CA (virtual)For Respondent: Shri Akhilesh Srivastva - Addl.CIT

Section 143(1)Section 154

mandatory in the sense that it cannot be waived or reduced by the I.T. authorities. The appellant has contended 5 ITA.No.1078/PUN/2025 that interest under section 234A, 234B and 234C of the Act, is not chargeable in case of Appellant being under liquidation under the provisions of Insolvency and Bankruptcy

Shri. Gajanan Urban Co-Op Credit Society Ltd., Hubballi vs. Income Tax Officer, Ward-2(1), Hubballi

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

ITA 80/BANG/2024[2019-20]Status: DisposedITAT Bangalore06 Jun 2025AY 2019-20

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan Kassessment Year : 2019-20

For Appellant: Shri. Gokul, AdvocateFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore

Section 119(2)(b)Section 139(1)Section 143Section 143(1)Section 143(1)(a)Section 234ASection 250Section 80PSection 80P(2)(a)

waiver with the Hon’ble Chief Commissioner ofIncome Tax/ Director General of Income Tax, the Appellant denies itself liable to be charged to interest under section 234A, 234B and 234C of the Act since it is not in accordance with the law as the rate, amount and the method

Schindler India Private Limited, Mumbai vs. Deputy Commissioner of Income Tax-Range 15(3)(2), Mumbai

ITA 7311/MUM/2018[2014-15]Status: DisposedITAT Mumbai06 Jun 2025AY 2014-15

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

Section 115Section 115JSection 143(3)Section 36(1)(va)

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “H” BENCH : MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND SHRI SANDEEP

Schindler India Pvt. Ltd., Mumbai vs. DCIT-Cir-15(3)(2), Mumbai

ITA 7326/MUM/2017[2013-14]Status: DisposedITAT Mumbai06 Jun 2025AY 2013-14

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

For Appellant: Ms. Chandani ShahFor Respondent: Shri Ajay Chandra, CIT-DR

Section 115Section 115JSection 143(3)Section 36(1)(va)

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “H” BENCH : MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND SHRI SANDEEP

Knowlarity Communications India Private Limited, Gurgaon, Haryana vs. Assistant Commissioner of Income Tax, Circle 14(2), Delhi

The appeal of the assessee is allowed partly

ITA 1420/DEL/2024[2017-2018]Status: DisposedITAT Delhi06 Jun 2025AY 2017-2018

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaassessment Year: 2017-18 Knowlarity Communications India Vs Acit, Private Ltd., Circle 14(2), Awfis, 7Th Floor, Delhi. Ambience Mall, Nh-8, Gurgaon, Haryana – 122 002. Pan : Aafck1875R (Appellant) (Respondent) Assessee By : Shri Salil Kapoor, Shri Shivam Yadav, Shri Sumit Lalchandani & Ms Ananya Kapoor, Advocates Revenue By : Ms Rajinder Kaur, Cit-Dr Date Of Hearing : 18.03.2025 Date Of Pronouncement : 06.06.2025 Order Per Anubhav Sharma, Jm:

For Appellant: Shri Salil KapoorFor Respondent: Ms Rajinder Kaur, CIT-DR

Section 143(3)Section 145Section 250Section 37Section 68

been properly considered and judicially interpreted. The observation/addition made is unjust, illegal, arbitrary, highly excessive and based on surmises and conjectures. 12. That interest under Section 234A, 234B and 234C of the Act has been wrongly and illegally charged and has been wrongly worked out. 13. That

Sohan Banwarilal Kumawat, Mumbai vs. Income Tax Officer-Ward 42(1)(5), Mumbai

In the result the appeal filed by the assessee stands partly allowed for statistical purposes

ITA 1778/MUM/2025[2012-13]Status: DisposedITAT Mumbai05 Jun 2025AY 2012-13

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 147Section 148Section 234ASection 68

available before him. 4. On the facts and circumstances of the case and law, the Ld. CIT(A) erred in confirming charging of interest under section 234A and 234B of Income Tax Act, 1961. 5. Appellant craves leave to add further grounds or to amend or alter the existing grounds

Aroti Ghosh, Allahabad vs. Income Tax Officer Ward-1(1), Allahabad

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

ITA 23/ALLD/2025[2008-09]Status: DisposedITAT Allahabad04 Jun 2025AY 2008-09

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 10(38)Section 143(2)Section 143(3)Section 147Section 234ASection 69

fact that proof of claim of deduction under Chapter-VI-A was never called for. 14. BECAUSE appellant denies for levy of interest under section 234A of the Act.” (B) At the time of hearing, learned Authorized Representative for the assessee drew our attention to ground No. 2 of appeal

Mahendra Singh Naruka, Jaipur vs. Assistant Commissioner of Income Tax, Central Circle-3, Jaipur

In the result, the appeal of the assesseein ITA no

ITA 205/JPR/2025[2016-17]Status: DisposedITAT Jaipur04 Jun 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं. / ITA. No. 204 & 205/JPR/2025 निर्धारणवर्ष / AssessmentYears : 2015-16 & 2016-17 Shri Mahendra Singh Naruka B-536, J.D.A. Colony Malivya Nagar, Jaipur 302 017 अपीलार्थी / Appellant स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.: ABUPN 1656 J बनाम Vs. The ACIT Central Circle-3 Jaipur प्रत्यर्थी / Respondent निधर्धारिती की ओरसे / Assesseeby : Shri S.R. Sharma, Advocate राजस्व की ओरसे /Revenue by : Mrs. Anita Rinesh

For Appellant: Shri S.R. Sharma, AdvocateFor Respondent: Mrs. Anita Rinesh, JCIT -DR a

Section 115BSection 143(3)Section 153ASection 68

Accordingly, these Grounds of Appeal are dismissed 7. Ground of Appeal No. 4 is as under: Ground No. 4. That the levy of interest under section 234A and 234B of the I.T Act, 1961 on the appellant is wrong and bad in law and is not correctly calculated

Mahendra Singh Naruka, Jaipur vs. Assistant Commissioner of Income Tax, Central Circle-3, Jaipur

In the result, the appeal of the assesseein ITA no

ITA 204/JPR/2025[2015-16]Status: DisposedITAT Jaipur04 Jun 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं. / ITA. No. 204 & 205/JPR/2025 निर्धारणवर्ष / AssessmentYears : 2015-16 & 2016-17 Shri Mahendra Singh Naruka B-536, J.D.A. Colony Malivya Nagar, Jaipur 302 017 अपीलार्थी / Appellant बनाम Vs. The ACIT Central Circle-3 Jaipur प्रत्यर्थी / Respondent स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.: ABUPN 1656 J निधर्धारिती की ओरसे / Assesseeby : Shri S.R. Sharma, Advocate राजस्व की ओरसे /Revenue by : Mrs. Anita Rinesh

For Appellant: Shri S.R. Sharma, AdvocateFor Respondent: Mrs. Anita Rinesh, JCIT -DR a

Section 115BSection 143(3)Section 153ASection 68

Accordingly, these Grounds of Appeal are dismissed 7. Ground of Appeal No. 4 is as under: Ground No. 4. That the levy of interest under section 234A and 234B of the I.T Act, 1961 on the appellant is wrong and bad in law and is not correctly calculated

Nitin Kumar Gupta, Haryana vs. Income Tax Officer Ward 19(3), C R Building ITO

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

ITA 3291/DEL/2024[2017-18]Status: DisposedITAT Delhi04 Jun 2025AY 2017-18

Bench: Shri Mahavir Singh & Shri M. Balaganeshnitin Kumar Gupta, Vs. Ito, J 1298B 4Th Floor, Palam Vihar, Ward-19(3), Haryana Delhi (Appellant) (Respondent) Pan: Ahtpg3074G

For Appellant: Shri Kunal Gupta, CAFor Respondent: Shri Amit Katoch, Sr. DR

Section 143(3)Section 234ASection 271A

record. 7. That on facts and in the circumstances of the case and in law, the Learned CIT (A) is confirming in charging interest under Section 234A, 234B, 234C of the Income Tax Act. 8. That on facts and in the circumstances of the case and in law, the Learned

Ramesh Kumar, Jhunjhunu vs. ITO Ward-1, Jhunjhunu

In the result, all the appeals of the assessee are allowed

ITA 1182/JPR/2024[2013-14]Status: DisposedITAT Jaipur03 Jun 2025AY 2013-14

For Appellant: Shri Sharwan Kumar Gupta, AdvocateFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR

Section 115BSection 147Section 148Section 151Section 234ASection 250Section 69

very basis of rectification under section 154 has been set aside by us as aforesaid, therefore, there remains no scope of charging interest under section 234A of the IT Act, 1961. On the above facts, we quash the order of the ld. CIT (A). Thus, the appeal of the assessee