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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
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

Iqvia Ag, Switzerland vs. The Income Tax Officer (International Taxation) - 2(2)(1), Mumbai

In the result, the appeal filed by the assessee is allowed in above terms

ITA 3359/MUM/2023[2020-21]Status: DisposedITAT Mumbai02 Dec 2025AY 2020-21

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhan

Section 142(1)Section 143(2)Section 144C(5)Section 90(2)

correctly after rectifying the above error apparent from the record and the excess consequential tax demand be deleted. Ground No. 4 - Levy of Interest under Section 234A of the Act of Rs. 4,62,147 1. On the facts and circumstances of the case and in law, the levy ... interest under Section 234A of the Act is consequential in nature and should be deleted or reduced once the relief as sought under Ground no. 1, 2 and 3 is allowed to the Appellant. Ground No. 5 – Levy of Interest under Section 234B

Gourav Bhagwandas Agarwal, Pune vs. ITO Ward 8(1), Pune

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

ITA 894/PUN/2025[2017-18]Status: DisposedITAT Pune28 Nov 2025AY 2017-18

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Digambar SurwaseFor Respondent: Shri Manish M. Mehta
Section 147Section 148Section 151Section 234ASection 69A

paid by the appellant. 7. On facts and circumstances of the case and law, learned AO erred in charging interest under section 234A, 234B of the Income Tax Act, 1961. 8. The appellant craves leave to add, alter, amend or delete any of the above grounds of appeal

Brijesh Chandwani, Hyderabad vs. DCIT., Circle -6(1), Hyderabad

In the result, appeal of the assessee for the assessment year 2020-2021 is allowed for statistical purposes

ITA 1528/HYD/2025[2020-2021]Status: DisposedITAT Hyderabad28 Nov 2025AY 2020-2021

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1527 & 1528/Hyd/2025 Assessment Years – 2016-2017 & 2020-2021 Brijesh Chandwani The Dcit, Circle-6(1), Vs. Hyderabad – 500 034 Hyderabad. Pan Adkpc1537H (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Pawan Kumar Chakrapani राज" व "ारा /Revenue By: Sri Ranjan Agrawala, Sr. Ar

For Appellant: CA Pawan Kumar ChakrapaniFor Respondent: Sri Ranjan Agrawala, Sr. AR
Section 133ASection 143(1)(a)Section 143(3)Section 147Section 148Section 148ASection 234A

recalculating the short term capital gain, under the facts and circumstances of the case. 10. The Appellant denies himself liable to interest under section 234A, 2348 and 234C of the Act, under the facts and circumstances of the case. 11. The Appellant craves leave to add, alter, delete or substitute

Brijesh Chandwani, Hyderabad vs. DCIT., Circle -6(1), Hyderabad

The appeal of the Assessee is allowed on this ground alone

ITA 1527/HYD/2025[2016-2017]Status: DisposedITAT Hyderabad28 Nov 2025AY 2016-2017
For Appellant: CA Pawan Kumar ChakrapaniFor Respondent: Sri Ranjan Agrawala, Sr. AR
Section 133ASection 143(1)(a)Section 143(3)Section 147Section 148Section 148ASection 234A

recalculating the short term capital gain, under the facts and circumstances of the case. 10. The Appellant denies himself liable to interest under section 234A, 2348 and 234C of the Act, under the facts and circumstances of the case. 11. The Appellant craves leave to add, alter, delete or substitute

Ravi Kant Luthra, Amritsar vs. Income Tax Officer Ward-1(1), Amritsar

In the result, the appeal of the assessee is allowed

ITA 444/ASR/2024[2021-22]Status: DisposedITAT Amritsar27 Nov 2025AY 2021-22

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Hybrid Hearing) I.T.A. No. 444/Asr/2024 Assessment Year: 2021-22 Ravi Kant Luthra, 1-Patel Vs. Adit, Cpc, Chowk Guru Bazar, Amritsar. Bengaluru. [Pan:-Alnpk7173Q] (Appellant) (Respondent) Sh. Himanshu Gupta, Ca Appellant By Respondent By Sh. Charan Dass, Sr. Dr

Section 115BSection 139(1)Section 143(1)Section 250Section 250(6)

Income Tax Returns for the assessment year 2021-2022 till March 31, 2022 - seeking order or direction, directing the respondents not to levy interest under section 234A till the revised due dates provided vide Circular 17/2021 dated 09.09.2021 - appropriate directions to authorities for accepting ... have been taken care of with view of what has been stated in the affidavit except the issue as regards the lew of interest under Section 234A of the Income Tax Act. We do not intend to look into the above controversy in the present litigation as we are informed

Shankaranarayana Constructions Private Limited, Bangalore vs. Asst. Commissioner of Income Tax, Central Circle - 2(4), C R Buildings, Queens Road, Bengaluru

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

ITA 1271/BANG/2025[2018-2019]Status: DisposedITAT Bangalore26 Nov 2025AY 2018-2019

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Respondent: Shri A. Shankar, Sr
Section 132Section 143Section 14ASection 153ASection 250

Apex Court in the case of Karanvir Singh 349 ITR 692, the Appellant denies itself liable to be charged to interest under section 234A, 234B & 234C of the Income Tax Act, on the facts and circumstances of the case. The appellant contends that the levy of interest under section 234A ... Apex Court in the case of Karanvir Singh 349 ITR 692, the Appellant denies itself liable to be charged to interest under section 234A, 234B & 234C of the Income Tax Act, on the facts and circumstances of the case. The appellant contends that the levy of interest under section 234A

Shankaranarayana Constructions Private Limited, Bangalore vs. Asst. Commissioner of Income Tax, Central Circle - 2(4), C R Buildings, Queens Road, Bengaluru

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

ITA 1270/BANG/2025[2017-2018]Status: DisposedITAT Bangalore26 Nov 2025AY 2017-2018

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Respondent: Shri A. Shankar, Sr
Section 132Section 143Section 14ASection 153ASection 250

Apex Court in the case of Karanvir Singh 349 ITR 692, the Appellant denies itself liable to be charged to interest under section 234A, 234B & 234C of the Income Tax Act, on the facts and circumstances of the case. The appellant contends that the levy of interest under section 234A ... Apex Court in the case of Karanvir Singh 349 ITR 692, the Appellant denies itself liable to be charged to interest under section 234A, 234B & 234C of the Income Tax Act, on the facts and circumstances of the case. The appellant contends that the levy of interest under section 234A

Shankaranarayana Constructions Private Limited, Bangalore vs. Asst. Commissioner of Income Tax- Central Circle 2(4), Central Revenue Building, Queens Road, Bengaluru

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

ITA 1269/BANG/2025[2016-2017]Status: DisposedITAT Bangalore26 Nov 2025AY 2016-2017

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Respondent: Shri A. Shankar, Sr
Section 132Section 143Section 14ASection 153ASection 250

Apex Court in the case of Karanvir Singh 349 ITR 692, the Appellant denies itself liable to be charged to interest under section 234A, 234B & 234C of the Income Tax Act, on the facts and circumstances of the case. The appellant contends that the levy of interest under section 234A ... Apex Court in the case of Karanvir Singh 349 ITR 692, the Appellant denies itself liable to be charged to interest under section 234A, 234B & 234C of the Income Tax Act, on the facts and circumstances of the case. The appellant contends that the levy of interest under section 234A

Shankaranarayana Constructions Private Limited, Sns House, Residency Road vs. Asst. Commissioner of Income Tax, Central Circle 2(4), Central Revenue Building, Queens Road, Bengaluru

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

ITA 1268/BANG/2025[2015-2016]Status: DisposedITAT Bangalore26 Nov 2025AY 2015-2016

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Respondent: Shri A. Shankar, Sr
Section 132Section 143Section 14ASection 153ASection 250

Apex Court in the case of Karanvir Singh 349 ITR 692, the Appellant denies itself liable to be charged to interest under section 234A, 234B & 234C of the Income Tax Act, on the facts and circumstances of the case. The appellant contends that the levy of interest under section 234A ... Apex Court in the case of Karanvir Singh 349 ITR 692, the Appellant denies itself liable to be charged to interest under section 234A, 234B & 234C of the Income Tax Act, on the facts and circumstances of the case. The appellant contends that the levy of interest under section 234A

Gbt India Private Limited, New Delhi vs. ACIT, OSD, Delhi

In the result, the assessee’s appeal is allowed as above

ITA 1764/DEL/2022[2018-19]Status: DisposedITAT Delhi26 Nov 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Section 143(3)Section 234ASection 36(1)(vii)Section 36(2)

Other Grounds 9. That, on the facts and circumstances of the case and in law, the Ld. AO erred in levying interest under Section 234A and 234B of the Act. 10. That, on the facts and circumstances of the case and in law, the Ld. AO erred in initiating penalty

Assps6238G, Noida vs. AO, Delhi

In the result, appeal of the assessee in ITA No

ITA 3270/DEL/2025[2014-2015]Status: DisposedITAT Delhi18 Nov 2025AY 2014-2015

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Nring Chamwibo Zellang, AdvFor Respondent: Ms. Ankush Kalra, Sr. DR
Section 147Section 234ASection 271(1)(b)

discarded and a fresh analysis for computing the taxable income should be considered Ground 6: The Ld. AO erred in charging interest under Section 234A, 234B and 234C. Ground 7: The Ld. AO has erred in law, facts and circumstances 7 in initiating penalty proceedings under Section

Rockwell Automation India Private Limited, Delhi vs. DCIT Circle-19(1), Delhi

Appeal is partly allowed for statistical purposes

ITA 3861/DEL/2024[2020-21]Status: DisposedITAT Delhi17 Nov 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalrockwell Automation India Deputy Commissioner Of Private Limited, Income Tax, Circle-19(1), Registered Address: 131, Vs. Delhi. Functional Industrial Are, Patparganj, Delhi-110092 Communication Address: 131, Functional Industrial Area, Patparganj, New Delhi. Pan-Aaccr3791A (Appellant) (Respondent) Assessee By Shri Ajit Jain, Ar Department By Shri Dharm Veer Singh, Cit-Dr Date Of Hearing 19.08.2025 Date Of Pronouncement 17.11.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Final Assessment Order Passed U/S 143(3) R.W.S 144C (13) Read With Section 144B Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) Dated 30.07.2024 For Assessment Year 2020-21. 2. Brief Facts Of The Case Ae That The Assessee Is A Company Engaged In The Business Of Manufacturing / Assembling Of Automation & Industrial Control Products / Systems. The Case Was Selected For Scrutiny & A Reference Was Made To The Tpo Due With Transactions With Ae’S. The Return Of Income Was Filed On Rockwell Automation India Private Limited Vs. Dcit 15.02.2021 Declaring Total Income At Rs.97,08,46,360/-. The Tpo Vide Its Order Dated 28.07.2023 Passed U/S 92Ca(3) Of The Act Has Proposed Adjustments Totaling To Rs. 26,12,44,668/-. Thereafter, The Ao Has Passed The Draft Assessment Order U/S 144C(1) Of The Act Dated 27.09.2023 Wherein The Ao Has Proposed The Additions Towards The Tp Adjustment As Per Tpo’S Order & Proposed To Assess The Total Income Of The Assessee At Rs.19,88,57,458/- & Further Proposed To Disallow Relief Claimed U/S 90/90A At Rs.1,04,60,287/-. Against The Draft Assessment Order, The Assessee Filed Objections Before The Drp.

Section 143(3)Section 144BSection 144C(1)Section 144C(10)Section 144C(13)Section 144C(8)Section 90Section 90ASection 92C

facts and in the circumstances of case and in law, the learned AO has erred in levying additional interest under section 234A, 234B and 234C of the Act on account of the additional tax liability which arose due to above erroneous additional made in the assessment order. 23. The Appellant

Jitendra Singh, Kanpur vs. ITO-1(3)(5), Kanpur

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

ITA 548/LKW/2024[2013-14]Status: DisposedITAT Lucknow13 Nov 2025AY 2013-14

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2013-14 Jitendra Singh, Vs. Income Tax Officer-1(3)(5), 107/2, Babu Purwa Colony, Kanpur Kidwai Nagar, Kanpur, U.P. Pan: Cvxps1754F (Appellant) (Respondent) Assessee By: Ms. Shweta Mittal, C.A. Revenue By: Sh. Prajesh Srivastava, Sr. Dr Date Of Hearing: 19.08.2025 Date Of Pronouncement: 13.11.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac Dated 12.07.2024 Dismissing The Appeal Of The Assessee Against The Order Under Section 154 Passed By The Assessing Officer On 22.07.2021. The Grounds Of Appeal Are As Under: - “1. That On Facts & In Law The Impugned Order Dated 12.07.2024 Passed By The Commissioner Of Income Tax (Appeals) U/S 250 Of The Income Tax Act, 1961 Is Bad In Law & Void-Ab-Initio. 2. That The Facts & In Law The Cit(Appeals) Have Erred In Passing The Impugned Appellate Order Without Considering The Request Of The Appellant That The Original Appeal Filed On 15.09.2019 For The Same A.Y. 2013-14 U/S 147/143(3) Of The I.T. Act, 1961, Before Cit(Appeals) Nfac Is Pending For Order So The Rectification Order U/S 154 By The A.O. For Enhancing The Demand Not Justified In Natural Justice. 3. That On Facts & In Law The Cit(Appeals) Has Erred In Not Follow The Provision U/S 115Bbe Properly As Per Law Of Income F Tax So, The Rectification Process U/S 154 Is Bad In Law. 4. That On Facts & In Law The Cit(Appeals) Has Erred In Upholding The Levy Of Interest U/S 234A & U/S 234B Of Income Tax Act, 1961 Without Considering The Original Appeal Filed On 15.09.2019 For The Same A.Y. 2013-14 U/S 147/143(3) Before Cit(Appeals) Nfac Is Pending For Order.

For Appellant: Ms. Shweta Mittal, C.AFor Respondent: Sh. Prajesh Srivastava, Sr. DR
Section 115BSection 147Section 154Section 234ASection 234BSection 250

Income Tax Act, 1961. Accordingly, it was proposed to rectify the same. Furthermore, in view of the delayed furnishing of the return, interest under section 234A was proposed to be levied. He, therefore, proceeded to complete the rectification on these lines. 4. The assessee is aggrieved at this order passed ... this appeal, but since section 115BBE was automatic in nature, the ld. AO had rightly applied the same to compute the tax and interest under section 234A and 234B were consequential in nature. Therefore, he did not find any grounds to interfere with the orders

Habib Agro Industries, Mandya vs. DCIT, Central Circle, Mysuru

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

ITA 1330/BANG/2025[2009-10]Status: DisposedITAT Bangalore13 Nov 2025AY 2009-10

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri V Srinivasan, AdvocateFor Respondent: Shri Shivanand H Kalakeri, CIT (DR)
Section 132Section 153ASection 234Section 234A

adjudication. Likewise, the . ITA No.1330 - 1335/Bang/2025 Page 3 of 12 Ground No. 4 of the assessee’s appeal pertains to the levy of interest under section 234A, 234B, and 234C of the Act which is consequential in nature and does not require any separate adjudication. Hence, Ground

Ahluwalia Erectors & Fabricators Private Limited, Kota vs. DCIT/ACIT Cir-2, Kota

In the result the appeal of

ITA 199/JPR/2025[2022-23]Status: DisposedITAT Jaipur12 Nov 2025AY 2022-23
For Appellant: Shri Mahendra Gargieya, AdvFor Respondent: Mrs. Anita Rinesh, JCIT
Section 143(1)Section 234ASection 250Section 438Section 43B

आयकरअपीलीय अधिकरण, जयपुरन्यायपीठ, जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, "A" JAIPUR डा० एस. सीतालक्ष्मी न्यायिक सदस्य एवं

Ahluwalia Erectors & Fabricators Private Limited, Kota vs. DCIT/ACIT Cir-2, Kota

In the result the appeal of

ITA 198/JPR/2025[2021-22]Status: DisposedITAT Jaipur12 Nov 2025AY 2021-22
For Appellant: Shri Mahendra Gargieya, AdvFor Respondent: Mrs. Anita Rinesh, JCIT
Section 143(1)Section 234ASection 250Section 43B

आयकरअपीलीय अधिकरण, जयपुरन्यायपीठ, जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”A” JAIPUR डा० एस. सीतालक्ष्मी न्यायिक सदस्य एवं

Ahluwalia Erectors & Fabricators Private Limited, Kota vs. DCIT/ACIT Cir-2, Kota

In the result the appeal of

ITA 197/JPR/2025[2019-20]Status: DisposedITAT Jaipur12 Nov 2025AY 2019-20
For Appellant: Shri Mahendra Gargieya, AdvFor Respondent: Mrs. Anita Rinesh, JCIT
Section 143(1)Section 234ASection 250Section 438Section 43B

आयकरअपीलीय अधिकरण, जयपुरन्यायपीठ, जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, “A” JAIPUR डा० एस. सीतालक्ष्मी न्यायिक सदस्य एवं

Gia India, Mumbai vs. A/DCIT (E) - 1(1), Mumbai

ITA 5429/MUM/2025[2017-18]Status: DisposedITAT Mumbai11 Nov 2025AY 2017-18

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 10Section 11Section 11(4)Section 2Section 2(15)Section 25Section 250

light of our decision on the primary issue of assessee's eligibility for exemption under section 11. With regard to levy of interest under section 234A (serial no.10) the ld AR submitted that the assessee for all the AYs have filed the return of income within the due date prescribed

Gia India, Mumbai vs. A/DCIT (E) - 1(1), Mumbai

ITA 5428/MUM/2025[2016-17]Status: DisposedITAT Mumbai11 Nov 2025AY 2016-17

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 10Section 11Section 11(4)Section 2Section 2(15)Section 25Section 250

light of our decision on the primary issue of assessee's eligibility for exemption under section 11. With regard to levy of interest under section 234A (serial no.10) the ld AR submitted that the assessee for all the AYs have filed the return of income within the due date prescribed

Gia India, Mumbai vs. A/DCIT (E) - 1(1), Mumbai

ITA 5427/MUM/2025[2015-16]Status: DisposedITAT Mumbai11 Nov 2025AY 2015-16

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 10Section 11Section 11(4)Section 2Section 2(15)Section 25Section 250

light of our decision on the primary issue of assessee's eligibility for exemption under section 11. With regard to levy of interest under section 234A (serial no.10) the ld AR submitted that the assessee for all the AYs have filed the return of income within the due date prescribed