“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

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

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

ITA 1180/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 144Section 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

Rajendra Kumar Samad, Jamshedpur vs. ITO Ward 2(4), Jamshedpur

In the result, grounds of appeal raised by the assessee are allowed

ITA 207/RAN/2023[2017-18]Status: DisposedITAT Ranchi30 May 2025AY 2017-18

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay(Virtual Hearing) Rajendra Kumar Samad, I.T.O., Dipasai, Kharswan, Saraikela-833216 Ward 2(4), Vs. (Jharkhand) Jamshedpur. Pan No. Fiops 6380 C Appellant/ Assessee Respondent/ Revenue

Section 143(2)Section 234Section 234ASection 89

liability. The ld. CIT(A) considered the grounds raised by the appeal, dismissed the appeal of the assessee on the ground that the interest under Section 234A, 234B and 234C is calculated irrespective of the fact that whether the appellant has claimed refund or not. The claim of refund made ... appellant was due to the fact that interest under Section 234A, 234B and 234C was not charged. ITA 207/Ran/2023 Rajendra Kumar Samad Vs ITO 4. Aggrieved by the order of ld. CIT(A), this appeal has been preferred by the assessee before the Tribunal. During the course of appellate proceedings

Deputy Commissioner of Income Tax, Noida vs. Formula One Marketing II Limited, United Kingdom

ITA 5092/DEL/2024[2012-13]Status: DisposedITAT Delhi30 May 2025AY 2012-13

Bench: Shri Shamim Yahya & Shri Sudhir Pareek

For Appellant: Shri Hiten Thakkar, AdvFor Respondent: Shri Surender Pal Singh, CIT(DR)

Section 148Section 154Section 195Section 209Section 234ASection 234B

final assessment order on 21 March 2018. Further, while computing the final tax liability for the year under consideration, the Learned AO applied interest under Section 234A of the Act for delay in filing the return ITA No.- 5092/Del/2024 Formula One Marke"ng II Limited of income and categorically

Mr. Kallimuddanahalli Thammannagowda Lokesh, Hassan vs. DCIT, Circle-1, Hassan

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

ITA 466/BANG/2025[2017-18]Status: DisposedITAT Bangalore29 May 2025AY 2017-18

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

For Appellant: Shri Siddesh Nagaraj Gaddi, CAFor Respondent: Ms. Neha Sahay, JCIT-DR

Section 143(1)Section 156Section 234ASection 246ASection 44A

IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH : BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE – PRESIDENT AND SHRI SOUNDARARAJAN K., JUDICIAL

Beauty Etoile Private Limited, Mumbai vs. Assessment Unit, Income Tax Department, Delhi

In the result, appeal of the assessee is allowed

ITA 4073/MUM/2024[2020-21]Status: DisposedITAT Mumbai29 May 2025AY 2020-21

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2020-21

For Appellant: Shri. Dharan Gandhi, AdvocateFor Respondent: Shri. Kiran Unavekar, Sr. DR

Section 143(3)Section 144Section 144CSection 144C(15)(b)Section 144C(5)Section 234Section 234ASection 270ASection 948

facts and circumstances of the case and in law, the Ld. AO erred in levying interest under section 234A of the Act. 12. On the facts and circumstances of the case and in law, the Ld. AO erred in computing interest under section

Australia and New Zealand Banking Group Limited, Mumbai vs. DCIT (International Tax) 1(1)(2), Mumbai

In the result, appeal by the assessee is allowed

ITA 4778/MUM/2024[2020-21]Status: DisposedITAT Mumbai28 May 2025AY 2020-21

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2020-21

For Appellant: Shri. Madhur Agrawal, AdvocateFor Respondent: Shri. Kiran Unavekar, Sr. DR

Section 133(6)Section 143(3)Section 144C(3)Section 144C(5)Section 153

erred in initiating penalty proceedings under section 270A of the Act for under-reporting of income. Ground no 5: Levy of interest under section 234A of the Act The learned AO erred in levying interest amounting to INR 1,91,277 under section 234A of the Act.” 2. The ground

Nagendra Kumar Singh, Patna vs. ITO, Ward-5(3), Patna

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

ITA 499/PAT/2024[2017-18]Status: DisposedITAT Patna26 May 2025AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 499/Pat/2024 Assessment Year: 2017-2018 Nagendra Kumar Singh,………..…..……..……Appellant Flat No. 204B, Terrace Gardenia Apartment, Near Laddu Gopal Sweets, Shiv Shambhu Colony, Ashiana Digha Road, Patna-800025, Bihar [Pan:Czsps0879N] -Vs.- Income Tax Officer,……………………………...Respondent Ward-5(3), Patna, Bihar Appearances By: Shri Abhi Sarkar, Advocate, Appeared On Behalf Of The Assessee Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: April 30, 2025 Date Of Pronouncing The Order: May 26, 2025 O R D E R

Section 142(1)Section 148Section 234A

assessment, the ld. Assessing Officer vide its order dated 22.11.2019 treated the total income of the assessee at Rs.15,60,220/- and charged interest under section 234A, 234B and 234C as per Rules. On being aggrieved, the assessee preferred an appeal before the ld. CIT(Appeals

Vanguard Total International Stock Index Fund, Mumbai vs. Assistant Commissioner of Income Tax (International Taxation)-4(3)(1), Mumbai

ITA 1283/MUM/2025[2022-23]Status: DisposedITAT Mumbai23 May 2025AY 2022-23

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

Section 143(2)Section 143(3)

with regard to the TDS credit and allow the claim in accordance with law. 12. Ground No.8 is with regard to levy of interest under section 234A to 234B of the Act. Ground No.11 is with regard to levy of penalty. These grounds being consequential do not warrant separate adjudication

Vanguard Total World Stock Index Fund, Mumbai vs. Assistant Commissioner of Income Tax (International Taxation)-4(3)(1), Mumbai

ITA 1281/MUM/2025[2022-23]Status: DisposedITAT Mumbai23 May 2025AY 2022-23

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

Section 143(2)Section 143(3)

Vanguard Funds Public Limited Company Vang Ftse Emerging Mkts Ucits Etf, Mumbai vs. Assistant Commissioner of Income Tax (International Taxation)-4(3)(1), Mumbai

ITA 1280/MUM/2025[2022-23]Status: DisposedITAT Mumbai23 May 2025AY 2022-23

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm Ι.Τ.Α. No. 1277/Mum/2025 (Assessment Year: 2022-23) Vanguard Emerging Markets Stock Index Fund A Series Of Visplc, C/O Ernst & Young Llp, 14Th Floor, The Ruby, 29, Senapati Bapat Marg, Dadar (West), Mumbai-400028. Pan: Aaccv3136B Appellant) Vs. Acit (It)-4(3)(1), Kautilya Bhavan, G Block, Bandra Kurla Complex, Maharashtra-400051. : Respondent) Ι.Τ.Α. No. 1278/Mum/2025 (Assessment Year: 2022-23) Vftc- Institutional Total International Stock Market Index Trust Ii, C/O Ernst & Young Llp, 14Th Floor, The Ruby, 29, Senapati Bapat Marg, Dadar (West), Mumbai-400028. Pan: Aadtv1640C Acit (It)-4(3)(1), Kautilya Bhavan, G Block, Bandra Kurla Complex, Vs. Maharashtra-400051. Appellant) : Respondent) Ι.Τ.Α. No. 1279/Mum/2025 (Assessment Year: 2022-23) Vanguard Emerging Markets Stock Index Fund A Series Of Vieif, C/O Ernst & Young Llp, 14Th Floor, The Ruby, 29, Senapati Bapat Marg, Dadar (West), Mumbai-400028. Vs. Acit (It)-4(3)(1), Kautilya Bhavan, G Block, Bandra Kurla Complex, Maharashtra-400051. Pan: Aaaty0918K Appellant) : Respondent) 2

Section 143(2)Section 143(3)

IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE MS PADMAVATHY S, AM & SHRI RAHUL CHAUDHARY, JM Ι.Τ

Vanguard Emerging Markets Stock Index Fund A Series of Vief, Mumbai vs. Assistant Commissioner of Income Tax (International Taxation)-4(3)(1), Mumbai

ITA 1279/MUM/2025[2022-23]Status: DisposedITAT Mumbai23 May 2025AY 2022-23

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

Section 143(3)

Vftc Institutional Total International Stock Market Index Trust II, Mumbai vs. Assistant Commissioner of Income Tax (International Taxation)-4(3)(1), Mumbai

ITA 1278/MUM/2025[2022-23]Status: DisposedITAT Mumbai23 May 2025AY 2022-23

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

Section 143(2)Section 143(3)

Vanguard Emerging Markets Stock Index Fund A Series of vs. Plc, Mumbaivs.Assistant Commissioner of Income Tax International Taxation -4(3)(1), Mumbai

ITA 1277/MUM/2025[2022-23]Status: DisposedITAT Mumbai23 May 2025AY 2022-23

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

Section 143(3)

Pragya Savita, Jabalpur vs. Asst. Commissioner of Income Tax, Circle 2(1), Jabalpur, Jabalur

In the result, the appeal of the assessee is dismissed

ITA 21/JAB/2025[2021-22]Status: DisposedITAT Jabalpur22 May 2025AY 2021-22

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2021-22 Pragya Savita, Vs. Asst. Commissioner Of 1197-A, Sadar, Modi Bada, Cantt, Income Tax, Circle-2(1), Jabalpur, Madhya Pradesh-482001 Jabalpur Pan:Axyps7485A (Appellant) (Respondent) Assessee By: Sh. Ashok Tiwari, Advocate Revenue By: Sh. Alok Bhura, Sr. Dr Date Of Hearing: 20.05.2025 Date Of Pronouncement: 22.05.2025 O R D E R Per Nikhil Choudhary, A.M. This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Jcit(A)-2, Vadodara Under Section 250 Of The Income Tax Act, 1961, Dated 27.10.2023, Dismissing The Appeal Of The Assessee That Was Filed Against The Order Of The Adit, Cpc, Bengaluru Under Section 143(1) Dated 17.12.2022. The Grounds Of Appeal Are As Under:- “1. That The Learned Cit (A) Nafc Was Wrong In Law For Not Allowing The Deduction For Payment Of Rs. 56,39,017/- Under Section 36(1)(Vi) On Account Of Employee Contribution Of Epf & Esic Amount. Whereas The Assessee Had Deposited The Employee Contribution Of Epf & Esic On Or Before Due Date For Furnishing Return Of Income Under Sub-Section (1) Of Section 139 Of Income Tax Act, 1961. Employer Is Entitled For Deduction. 2. That The Both Employee Contribution Epf Rs.49,38,777/- & Esic Rs.70,0240/- Total Rs. 59,39,107/-Which Has Been Deposited With A Small Delay Due To Unavoidable Circumstances & Covid-19. Whereas The Assessee Had Deposited The Employee Contribution Before Filing Of The Return.

For Appellant: Sh. Ashok Tiwari, AdvocateFor Respondent: Sh. Alok Bhura, Sr. DR

Section 139Section 143(1)Section 234ASection 234BSection 234CSection 250Section 36(1)(vi)

account of employee contribution of EPF and ESIC when contribution had been paid prior to filing of the return. 5. Charges of interest under section 234A, 234B &234C. That the unreasonable high interest charged against the principle of natural justice, the interest U/s 234A Rs.1,60,801.00,U/s 234B Rs.7

Rajesh Kumar, Uttar Pradesh vs. Assessing Officer, National Faceless Assessment Cente(NFAC), Delhi, New Delhi

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

ITA 784/LKW/2024[2018-19]Status: DisposedITAT Lucknow22 May 2025AY 2018-19

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

For Appellant: NoneFor Respondent: Shri Amit Kumar, D.R

Section 115BSection 147Section 148Section 234ASection 271ASection 69ASection 69C

basis of facts and circumstances of the case, Ld. AO has erred both in law as well as on facts in charging interest under section 234A and 234B of the of the 1.T. Act 1961. 9. The appellant reserves the right to add, amend and delete

Rajesh Kumar, Uttar Pradesh vs. Assessing Officer, National Faceless Assessment Center(NFAC), Delhi, New Delhi

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

ITA 783/LKW/2024[2018-19]Status: DisposedITAT Lucknow22 May 2025AY 2018-19

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

For Appellant: NoneFor Respondent: Shri Amit Kumar, D.R

Section 115BSection 147Section 148Section 234ASection 271ASection 69ASection 69C

Narayana Rao Hebri, Sagar vs. The Assistant Commissioner of Income Tax, Circle-1, Shivamogga

In the result, the appeal of assessee is partly allowed

ITA 2051/BANG/2024[2017-18]Status: DisposedITAT Bangalore22 May 2025AY 2017-18

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

For Appellant: Shri Tata Krishna, AdvocateFor Respondent: Shri V. Parithivel, Jt.CIT(DR)(ITAT), Bengaluru

Section 115BSection 143(3)Section 144Section 68

under section 234A of the Act: 6.1. The Learned Assessing Officer is not right in law and on facts in levying interest under section 234A of Rs. 2,97,176/ -. 6.2. The Learned Assessing Officer is not justified in levying the aforesaid interest when the impugned addition is not tenable

Deputy Commissioner of Income Tax, Central Circle - 2(4), Bengaluru vs. Sri Adichunchanagiri Shikhana Trust, Mandya

ITA 1207/BANG/2024[2011-12]Status: DisposedITAT Bangalore22 May 2025AY 2011-12

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: Shri Bharath L, CAFor Respondent: Smt. Vidya K., Jt.CIT (DR)(ITAT), Bengaluru

Section 143(3)Section 234ASection 69ASection 69C

same is exigible to tax under the facts and circumstances of the case. 12. The LAO erred in computing the consequential interest under Section 234A, 234B and 234C of the Act. 13. The Appellant craves leave to add, alter, amend, substitute change and delete any of the grounds of appeal ... with the provisions of the Act to the extent they are prejudicial to the Appellant. 12. The LAO erred in computing the consequential interest under Section 234A, 234B and 234C of the Act. 13. The Appellant craves leave to add, alter, amend, substitute change and delete any of the grounds

M/S. Sri . Adichunchanagiri Shilkshana Trust, Mandya vs. The Deputy Commissioner of Income Tax, Central Circle-2(4), Bengaluru

ITA 1096/BANG/2024[2011-12]Status: DisposedITAT Bangalore22 May 2025AY 2011-12

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: Shri Bharath L, CAFor Respondent: Smt. Vidya K., Jt.CIT (DR)(ITAT), Bengaluru

Section 143(3)Section 69ASection 69C

same is exigible to tax under the facts and circumstances of the case. 12. The LAO erred in computing the consequential interest under section 234A, 234B and 234C of the Act. 13. The Appellant craves leave to add, alter, amend, substitute change and delete any of the grounds of appeal ... Nos.1096 & 1207/Bang/2024 provisions of the Act to the extent they are prejudicial to the Appellant. 12. The LAO erred in computing the consequential interest under section 234A, 234B and 234C of the Act. 13. The Appellant craves leave to add, alter, amend, substitute change and delete any of the grounds

Smt. Ranjana Bajpai, Allahabad vs. DCIT/ACIT Circle 1(!), Allahabad

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

ITA 150/ALLD/2024[2014-15]Status: DisposedITAT Allahabad21 May 2025AY 2014-15

Bench: SH. SUBHASH MALGURIA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Ajit Kumar, AdvocateFor Respondent: Sh. A.K. Singh, Sr. DR

Section 139Section 142Section 143Section 144Section 250

power vested in the Authorities. 7. BECAUSE the Ld. CIT(A) is not justified on facts and in law to affirm charging of interest under section 234A & 234B of the Act. 8. BECAUSE the Ld. CIT(A) is not justified in not deciding the issue related to initiation