“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

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

Tata Aig General Insurance Company Limited (Tagic), Mumbai vs. Assessment Unit, Income-Tax Department

ITA 1432/MUM/2024[2020-21]Status: DisposedITAT Mumbai05 Mar 2026AY 2020-21

Bench: Shri Anikesh Banerjee & Shri Jagadish

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Ritesh Misra (CIT DR)

Section 10(38)Section 111ASection 112Section 139(1)Section 143(3)Section 234ASection 234BSection 234DSection 250

facts and circumstances of the case and in law, erred in confirming the action of the learned AO in levying interest under section 234A, by holding that levy of such interest is mandatory and consequential in nature, while no such levy was permissible as per section 234A

Hotel Maleekara Pattina Souharda Sahakaari Sangha Niyamitha, Tumkur vs. Income Tax Officer, Ward-1 & Tps, Tumkur

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

ITA 1110/BANG/2025[2017-18]Status: DisposedITAT Bangalore03 Mar 2026AY 2017-18

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri A. Shivaram, CA

Section 142(1)Section 143(2)Section 234ASection 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

Income Tax Act, 1961. 3. The Hon'ble CIT has erred in law by levying Interest under section 234A & 234B of the Income Tax Act, 1961. Page 2 of 6 4. The appellant craves leave to add, to amend and/or alter any of the foregoing grounds and such other grounds

Karnataka Industrial Areas Development Board, Bangalore vs. Deputy Commissioner Income Tax, Exemptions, Circle-1, Bangalore

ITA 355/BANG/2024[2017-18]Status: DisposedITAT Bangalore02 Mar 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Sudheendra B.R, AdvocateFor Respondent: Shri Shivanand H Kalakeri, CIT-DR

Section 11Section 11(1)Section 13(8)Section 143(3)Section 153(1)Section 2(15)Section 250Section 43B

income of earlier years should be set off with the income assessable. if any, for the year under consideration. 7. Levy of interest under section 234A and 234B 7.1 The learned AO/CIT(A) erred in levying / confirming the levy of interest under section 234A and 234B. On facts and circumstances ... case and law applicable, interest under section 234A and 234B is not leviable. The appellant denies its liability to pay interest under section 234A and 234B. 8. Prayer 8.1. In view of the above and other grounds to be adduced at the time of hearing, the appellant prays that

Karnataka Industrial Areas Development Board, Bangalore vs. Deputy Commissioner of Income-Tax, Exemptions, Circle-1, Bangalore

ITA 354/BANG/2024[2016-17]Status: DisposedITAT Bangalore02 Mar 2026AY 2016-17

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Sudheendra B.R, AdvocateFor Respondent: Shri Shivanand H Kalakeri, CIT-DR

Section 11Section 11(1)Section 13(8)Section 143(3)Section 153(1)Section 2(15)Section 250Section 43B

income of earlier years should be set off with the income assessable, if any, for the year under consideration. 7. Levy of interest under section 234A and 234B 7.1 The learned AO/CIT(A) erred in levying / confirming the levy of interest under section 234A and 234B. On facts and circumstances ... case and law applicable, interest under section 234A and 234B is not leviable. The appellant denies its liability to pay interest under section 234A and 234B. 8. Prayer 8.1. In view of the above and other grounds to be adduced at the time of hearing, the appellant prays that

S B Manghanani Chartiable, Bangalore vs. Income Tax Officer, Exemptions, Ward-3, Bangalore

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

ITA 1508/BANG/2024[2016-17]Status: DisposedITAT Bangalore02 Mar 2026AY 2016-17

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2016-17

For Appellant: Ms. Ema Bindu, AdvocateFor Respondent: Shri Subramanian .S, JCIT-DR

Section 11Section 11(2)Section 139(1)Section 142(1)Section 143(2)Section 234ASection 250

capita assets was not claimed as application, 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

Manish Bhogilal Shah, Mumbai vs. Income Tax Officer-3, Navsari

In the result, the appeal of the assessee is treated as allowed for statistical purpose

ITA 687/SRT/2025[2017-18]Status: DisposedITAT Surat27 Feb 2026AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.687/Srt/2025 िनधा"रण वष" /Assessment Year : 2017-18 Manish Bhogilal Shah The Income Tax Officer-3 बनाम/ 6/B, Crown Mansion Navsari – 396 445 V/S. Ground Floor Forjeet Street, Cross Lane, Mumbai – 400 026 "थायी लेखा सं./Pan: Acqps 6699 F (अपीलाथ(/ Appellant) (!) यथ(/ Respondent) Assessee By : Shri Himanshu Gandhi, Ca Revenue By : Shri Ajay Uke, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 08 /12/2025 घोषणा की तारीख /Date Of Pronouncement: 27 /02/2026 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 27/12/2024 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal: Manish Bhogilal Shah Vs. Ito Asst. Year : 2017-18 2

For Appellant: Shri Himanshu Gandhi, CAFor Respondent: Shri Ajay Uke, Sr.DR

Section 147Section 234ASection 250Section 271ASection 68Section 69C

Ground 7. On the facts and circumstances of the case and law. the Ld. CIT(A) erred in confirming charging of interest under section 234A, 234B, 234C and 234D of the Income Tax Act, 1961. 2. Ground 8. On the facts and circumstances of the case

Charak Helth Care & Rural Development Society, Lucknow vs. DCIT-CC-2, Lucknow

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

ITA 412/LKW/2024[2013-14]Status: DisposedITAT Lucknow27 Feb 2026AY 2013-14

Bench: SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Suyash Agarwal, AdvFor Respondent: Sh. Vachaspati Tripathi, CIT DR

Section 11Section 12ASection 143(1)Section 234ASection 250

disallowing the application towards charitable purposes and raised a demand of Rs. 1,53,41,780/- alongwith interest under section 234A, 234B and 234C. The assessee did not receive any order of its return not having been accepted in a physical mode and it was unaware of this fact

Bobst Bielefeld Gmbh, Germany vs. The Assistant Commissioner of Income Tax Int Tax Circle 1(3)(1), Mumbai

ITA 6030/MUM/2025[2018-19]Status: DisposedITAT Mumbai26 Feb 2026AY 2018-19

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

For Appellant: Shri Siddesh ChauguleFor Respondent: Shri Krishna Kumar, Sr.DR

Section 234Section 234ASection 270A

Accordingly, Ld. CIT(A) has erred in upholding the order passed by Ld. AO. 4. Ground No. 4-Incorrect calculation of Interest under section 234A, 234B and 234C of the Act On the facts and in the circumstances of the case and in law, consequential erroneous interest liability under sections

Bobst Bielefeld Gmbh, Germany vs. The Assistant Commissioner of Income Tax Int Tax Circle 1(3)(1), Mumbai

ITA 6029/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

For Appellant: Shri Siddesh ChauguleFor Respondent: Shri Krishna Kumar, Sr.DR

Section 234Section 234ASection 270A

The Vandeli Dudh Utpadak Sahakari Mandli Ltd, Panchmahal vs. The ITO, Ward-1, Godhra

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

ITA 1875/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad25 Feb 2026AY 2019-20

Bench: Ms. Suchitra Kambleassessment Year 2019-20

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri Rameshwar P. Meena, Sr. D.R

Section 148Section 234ASection 250(6)Section 271ASection 68Section 80PSection 80P(2)(d)

Income Tax Act, 1961. 8.0 The learned Commissioner of Income Tax (Appeals), NFAC erred in law and on facts has confirmed the charging interest under section 234A, 234B and 234F of the Income Tax Act, 1961. 9.0 The appellant craves leave to add to, alter, delete or modify

Rajesh Sarda, Nagpur vs. Assistant Commissioner of Income Tax, Central Circle-2(2), Nagpur

In the result, the addition of undisclosed income under section 68 is deleted

ITA 44/NAG/2022[2015-16]Status: DisposedITAT Nagpur24 Feb 2026AY 2015-16

Bench: Shri Pawan Singh & Shri Khettra Mohan Roy(Physical Hearing) Rajesh Sarda, Acit, Central Circle – 2(2), Nagpur 14, Daga Lay–Out, Ambazari Road, Vs Aayakar Bhawan, Civil Lines, Nagpur – 440033. Maharashtra – 440001. [Pan: Ahaps4925M] Appellant / Assessee Respondent / Revenue Assessee By Shri K.P. Dewani, Advocate Revenue By Shri Pankaj Kumar, Cit–Dr Date Of Hearing 16.02.2026 Date Of Pronouncement 24.02.2026 Order Under Section 254(1) Of Income Tax Act

Section 10(38)Section 132Section 153ASection 234ASection 254(1)Section 68Section 69C

deleted the addition made as the procedure is in complete violation with settled propositions of law. 7) The assessee denies liability to pay interest under section 234A, 234B and 234C of I.T. Act 1961. Without prejudice, levy of interest under section 234A, 2334B and 234C

Goldman Sachs Services Private Limited, Bangalore vs. DCIT, Circle 3(1)(1), Bangalore

ITA 2525/BANG/2024[AY 2021-22]Status: DisposedITAT Bangalore23 Feb 2026

Bench: MS. PADMAVATHY S., ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Madhur AgarwalFor Respondent: Dr. Divya K. J

Section 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 234ASection 270ASection 92C

proposing to initiate penalty proceedings under section 270A of the Act for under-reporting of income. 3. Ground No. 3: Incorrect levy of interest under section 234A, 234B and 234C of the Act The learned AO, erred in law and facts, on levying consequential interest under section 234A ... No.2525/Bang/2024 Assessment Year 2021-2022 in nature. Ground No.3 26. Ground No. 3 raised by the Assessee pertains to incorrect levy of interest under Section 234A, 234B and 234C of the Act is dismissed as consequential in nature. 27. In terms of above, the present appeal preferred by the Assessee

Nagpur District Shala Karmachari Credit Co-Operative Society Ltd, Nagpur vs. Income Tax Officer Ward 4 (4), Nagpur

In the result, assessee's appeal is allowed

ITA 775/NAG/2025[2020-21]Status: DisposedITAT Nagpur19 Feb 2026AY 2020-21

For Appellant: Shri K P Dewani (through virtual)For Respondent: Shri Surjit Kumar Saha Sr.DR (through virtual)

Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

held that entire income of assessee is eligible for deduction u/s 80P of IT Act 1961 5. The assessee denies liability to pay interest under section 234A, 234B and 234C of I.T. Act 1961. Without prejudice, levy of interest under section 234A, 234B and 234C

Nagpur District Shala Karmachari Credit Co-Operative Society Ltd, Nagpur vs. Income Tax Officer Ward 4 (4), Nagpur

In the result, assessee’s appeal is allowed

ITA 774/NAG/2025[2018-19]Status: DisposedITAT Nagpur19 Feb 2026AY 2018-19

Bench: Shri R. K. Panda

For Appellant: Shri K P Dewani (through virtual)For Respondent: Shri Surjit Kumar Saha Sr.DR

Section 234ASection 80PSection 80P(2)(a)Section 80P(2)(d)

Mps Family Trust, Agra vs. ITO, Ward-1(1)(1), Agra

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

ITA 562/AGR/2025[2020-21]Status: DisposedITAT Agra18 Feb 2026AY 2020-21

Bench: : Shri S. Rifaur Rahmanassessment Year: 2020-21 Mps Family Trust Vs. Ito, A-25 New Shahganj, Ward-1, Morena Agra Pan : Aaftm7275G (Appellant) (Respondent) Assessee By Sh. Anurag Sinha, Adv. Department By Shri Anil Kumar, Sr. Dr Date Of Hearing 18.02.2026 Date Of Pronouncement 18.02.2026 Order

Section 144Section 147Section 148Section 234ASection 250(6)Section 69

cross-examine or rebut the same, which is in violation of principles of natural justice. 10. BECAUSE, the 'appellant' denies levy of interest under section 234A and 234B of the 'Act' and in any case same are not in accordance with law and excessive. 11. BECAUSE, in any view

Kca Co Operative Cerdit Society, Mumbai vs. Mum-(197)(91), Mumbai

In the result, appeal of the assessee is dismissed

ITA 6585/MUM/2025[2013-2014]Status: DisposedITAT Mumbai18 Feb 2026AY 2013-2014

Bench: Shri Sandeep Gosain

For Respondent: Shri Brajendra Kumar, (Sr. DR)

Section 143(1)Section 234ASection 249(3)Section 80PSection 80P(2)(d)Section 8o

from the Cooperative Banks eligible for deduction us 80P 2d of Rs 9,76,373. The learned Assessing Officer further erred in levying interest under section 234A,234B and 234C of Rs.6,032, Rs.54,288 and Rs.11,159 respectively. 2. Your Petitioner further states that the learned CIT(A) also

Vijay Lalitchandra Parekh, Mumbai vs. Assistant Commissioner of Income Tax 25.1, Kautilya Bhuvan

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

ITA 5155/MUM/2025[2011-2012]Status: DisposedITAT Mumbai18 Feb 2026AY 2011-2012

Bench: Hon’Ble Shri Sandeep Gosain& Hon’Ble Shri Bijayananda Prusethvijay Lalitchandra Parekh Vs. Assistant Commissioner Vastu Subh A Wing Ground Of Income Tax 25.1 Floor Rajamata Jijabai Road Kautilya Bhuvan Bkc Pump House Andheri East, Bandra East, Mumbai – 400093 Mumbai- 400051 Pan/Gir No. Aiupp3044K (Applicant) (Respondent)

Section 143(2)Section 143(3)Section 145Section 148Section 234ASection 250Section 68

Accounts invoking provision of section 145 of the Act. 6. The learned Commissioner of Income Tax Appeals erred in confirming charging of interest under section 234A, 234B, 234C and 234D of the Act. 7. The appellant crave leave to add, amend, alter and/OR vary any of the grounds of appeal

Megha Kishor Dalvi, Pune vs. ITO Ward 6(1), Pune

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

ITA 955/PUN/2025[2018-19]Status: DisposedITAT Pune17 Feb 2026AY 2018-19

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.955/Pun/2025 निर्धारण वर्ा / Assessment Year : 2018-19 Megha Kishor Dalvi, Vs. Ito, Ward-6(1), Pune 27 Amruta Apartment, Sinhagad Road, Anandnagar Manik Baug, Pune-411051 Pan : Ajopd8763C Appellant Respondent

For Appellant: Smt. Deepa KhareFor Respondent: Shri Uodol Raj Singh, DR

Section 144Section 144BSection 147Section 148Section 148ASection 234ASection 69

circumstances of the case. 5. On facts and circumstances of case and in law, learned CIT(A) erred in charging and leaving interest under section 234A and 2348. 6. Your Appellant craves leave to add to, alter, amend, modify and/ or delete any or all of the above said ground

Jagdeep Singh Dhanoa, United Arab vs. Income Tax Officer It 2(1) (1), Mumbai

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

ITA 1681/MUM/2022[2017-18]Status: DisposedITAT Mumbai17 Feb 2026AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankarjagdeep Singh Dhanoa Vs. Income Tax Officer, 8202, 23 Marina, Po Pox It (2)(1), Mumbai 73392, Dubai Marina Dubai 1724, 17Th Floor, Air Ar, Foreign, India Building, United Arab Emirates- Nariman Point, 73392 Mumbai - 400021 Pan/Gir No. Aadpd4843R (Applicant) (Respondent) Assessee By None Revenue By Shri Krishna Kumar (Sr. Dr.) Date Of Hearing 03.02.2026 Date Of Pronouncement 17.02.2026 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order 26.04.2022 Passed U/S 143(3) R.W.S. 144C Of The Income Tax Act, 1961 (‘The Act’), By The Office Of The Income Tax Officer Ward 2(1) (1), Mumbai For The Assessment Year 2017-18. The Following Grounds Are Reproduced Below:

Section 143(3)Section 234ASection 234B

rate of interest that may be considered by the id. TPO during the course of transfer pricing proceedings. 4) Error in calculation of interest under section 234A and 234B of the Act: 4.1 The Ld. AO had erred in calculating the interest u/s 234A of the Act, for delay

Santosh Laxman Malusare, Pune vs. ITO, Ward-5(2), Pune

In the result, appeal of the assessee is allowed

ITA 3075/PUN/2025[2015-16]Status: DisposedITAT Pune16 Feb 2026AY 2015-16

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.3075/Pun/2025 निर्धारण वषा / Assessment Year: 2015-16 Santosh Laxman Malusare, Vs Ward-5(2), Pune. Lahagaon, Moze Ali Haveli, Pune – 411047. Pan: Awzpm1600M Appellant/ Assessee Respondent /Revenue Assessee By Shri Rushab Shah Revenue By Shri Ajitesh Kumar Meena – Addl.Cit Date Of Hearing 27/01/2026 Date Of Pronouncement 16/02/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2015-16 Dated 14.10.2025 Emanating From The Assessment Order Passed Under Section 147 Read With Section 144B Of The I.T.Act, 1961 Dated 24.11.2023. The Assessee Has Raised Following Grounds Of Appeal : “1. On The Facts & Circumstances Prevailing In The Case & As Per The Provisions & Scheme Of The Act, It Be Held That Re-Opening Of The

Section 144BSection 147Section 148Section 148ASection 149Section 234ASection 250Section 698

That on the Facts and in the Circumstances of the Case and in Law, the Ld. Assessing officer has erred by computing interest under section 234A & 2348 while computing total demand. As such the said interest may please be deleted. 6. That the appellant craves, leave to add, alter, amend