“interest u/s 234A”

InterestSection 234ASection 234A1,483 judgments

The decision most relied on for interest u/s 234A is CIT v. Ranchi Club Ltd. (247 ITR 209), cited in 21 judgments on BharatTax.

Leading authorities on interest u/s 234A

CIT v. Ranchi Club Ltd.

247 ITR 209 · 2001 · Supreme Court

citing judgments

Interest under sections 234A and 234B cannot be levied mechanically when there is a reasonable cause for delay in payment or response to notices.

ACIT v. Hans Raj Gandhi

37 ITR 418 · Reported

citing judgments

An assessee is entitled to the adjustment of seized cash against their advance tax liability. Consequently, no interest under sections 234A or 234B can be charged if the department fails to respond to the assessee's request for such an adjustment.

Judgments citing interest u/s 234A

Sanchit Kantilal Ganore, Bhagur vs. ITO Ward 1(1), Nashik

In the result, appeal of the assessee is partly allowed

ITA 1767/PUN/2025[2017-18]Status: DisposedITAT Pune19 Sept 2025AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1767/Pun/2025 निर्धारण वषा / Assessment Year: 2017-18 Sanchit Kantilal Ganore, V The Income Tax Officer, 21, Main Road, Bhagur, S. Ward-1(1), Nashik. Nashik - 422502. Pan: Aprpg4907J Appellant/ Assessee Respondent / Revenue Assessee By Shri Piyush Bafna Revenue By Shri Aviyogi Ambadkar– Add.Cit(Dr) Date Of Hearing 09/09/2025 Date Of Pronouncement 19/09/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is 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 A.Y.2017-18, Dated 29.05.2025 Emanating From Assessment Order U/S.147 R.W.S 144 Of The I.T.Act, Dated 21.05.2023. The Assessee Has Raised Following Grounds Of Appeal : “1. On The Facts & In The Circumstances Of The Case & In Law & Without Prejudice To Other Grounds, Ld. Nfac Has Erred In Passing A

Section 147Section 148Section 149Section 151Section 250

circumstances of the case and in law and without prejudice to any other ground, Ld. NaFAC has erred in levying interest u/s 234A, 234B & 234C and hence, the same may please be quashed. 18. On the facts and in the circumstances of the case and in law and without prejudice

M/S. Shring Construction Company Pvt. Ltd., Dehradun vs. ACIT, Muzaffarnagar

In the result, appeal of the assessee is partly allowed

ITA 3308/DEL/2017[2013-14]Status: DisposedITAT Delhi19 Sept 2025AY 2013-14

Bench: Shri Anubhav Sharma & Shri Manish Agarwal{ M/S Shring Construction Asst. Cit, Company Pvt. Ltd., Circle-2, D-245, Nehru Colony, Vs. Muzaffar Nagar. Haridwar Road, Dehradun. Pan:Aabcr4560L (Appellant) (Respondent) Assessee By Shri Ankit Gupta, Adv. Department By Shri Narpat Singh, Sr. Dr Date Of Hearing 26.06.2025 Date Of Pronouncement 19.09.2025

Section 143(2)Section 143(3)Section 250Section 40Section 40A(3)Section 68

principles of natural justice and the same has been passed without affording reasonable and adequate opportunity of being heard. 11. That the interest U/s 234A, 234B, 2340 & 234C has been wrongly and illegally charged as the appellant could not have foreseen the disallowances/additions made and could not have included ... appeal No.8, 9 and 10 are general in nature needs no adjudication. 20. Ground of appeal No.11 is with respect to levy of interest U/s 234A, 234B, 234C & 234C which are consequential in nature and AO is defected to charge interest as per law. 21. In the result, appeal

Shri Subhas Hansaraj Nandu, Bhachau-Kutch vs. The ACIT, Gandhidham Circle, Gandhidham-Kutch

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

ITA 10/RJT/2024[2014-15]Status: DisposedITAT Rajkot18 Sept 2025AY 2014-15

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 10/Rjt/2024 ("नधा"रणवष" / Assessment Year: (2014-15) (Hybrid Hearing) Subhas Hansaraj Nandu, V Acit, Gandhidham Opp. Shambhu Maharaj Circle, S Bunglow, Kutch . Bhachau, Gujarat – 370140 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Afrpn0720J (Appellant) (Respondent) Appellant By : Shri Kalpesh Doshi, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 143(3)Section 144Section 234ASection 250Section 271(1)(c)Section 37(1)Section 41(1)

penalty proceeding u/s 271(1)(c) of the I.T. Act, 1961. 7. That, the Ld. CIT(A) has wrongly confirmed levy of interest u/s 234A, 234B, 234C and 234D of I.T. Act, 1961. 8. That, the findings of the Ld. AO and Ld. CIT(A) are not justified

Rajesh Kumar, Patna vs. ITO, Ward- 3 (2), Gaya

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

ITA 171/PAT/2025[2018-19]Status: DisposedITAT Patna18 Sept 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 147Section 234ASection 250Section 271FSection 69A

fact and in the circumstances of the appellants. 7. For that the Ld. CIT (A) NFAC has erred in affirming charging of interest u/s 234A and 234B amounting to Rs.47,71,305/- and Rs.52,05,060/- respectively. 8. For that the appellant may not be treated as assessee in default

Mo. Shariph Kureshi, Sikar vs. ITO Ward-4 Sikar, Sikar

In the result, the appeal of the assessee is allowed

ITA 366/JPR/2025[2013-14]Status: DisposedITAT Jaipur18 Sept 2025AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Shrawan Kumar Gupta, AdvFor Respondent: Shri Gautam Singh Choudhary, JCIT

Section 144Section 147Section 148Section 234ASection 271(1)(c)

make kindly be deleted. 4. The ld.AO has grossly erred in law as well as on facts of the case, in charging interest u/s 234A,B,C. The interest so charged is totally contrary to the provisions of law and facts of the case and hence may kindly be deleted

Dodhia Filaments Private Limited, Bhiwandi vs. DCIT-CC-3, Thane

ITA 795/MUM/2025[2013-14]Status: DisposedITAT Mumbai17 Sept 2025AY 2013-14

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 147Section 250Section 68

circumstances of the assessee’s case and in law, the Ld. Commissioner of Income Tax (Appeals) erred in upholding the levy of interest u/s 234A, 234B and 234C of the Income Tax Act, 1961. 9. On the facts and in the circumstances of the assessee’s case

Dodhia Synthetics Limited, Bhiwandi vs. DCIT-CC-3, Thane

ITA 2204/MUM/2025[2020-21]Status: DisposedITAT Mumbai17 Sept 2025AY 2020-21

Section 143(3)Section 147Section 250Section 68

Commissioner of Income Tax (Appeals) and in law, the Ld. Commissioner of Income Tax (Appeals) erred in upholding the levy of interest u/s 234A, 234B and 234C of the Income Tax Act, 1961. 9. On the facts and in the circumstances of the assessee's case

Dodhia Synthetics Limited, Bhiwandi vs. DCIT-CC-3, Thane

ITA 2189/MUM/2025[2013-14]Status: DisposedITAT Mumbai17 Sept 2025AY 2013-14

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 147Section 250Section 68

DCIT, Central Circle -3, Thane vs. Dodhia Synthetics Limited, Bhiwandi

ITA 2106/MUM/2025[2015-16]Status: DisposedITAT Mumbai17 Sept 2025AY 2015-16

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 147Section 250Section 68

DCIT, Central Circle -3, Thane vs. Dodhia Synthetics Limited, Bhiwandi

The appeal of the assessee is Allowed on the

ITA 2105/MUM/2025[2014-15]Status: DisposedITAT Mumbai17 Sept 2025AY 2014-15

Section 143(3)Section 147Section 250Section 68

circumstances of the assessee's case and in law, the Ld. Commissioner of Income Tax (Appeals) erred in upholding the levy of interest u/s 234A, 234B and 234C of the Income Tax Act, 1961. 9. On the facts and in the circumstances of the assessee's case

Kamal Kant, Delhi vs. ITO, Ward-54(1), Delhi

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

ITA 3594/DEL/2023[2009-10]Status: DisposedITAT Delhi17 Sept 2025AY 2009-10

Bench: Sh. Sudhir Kumar & Sh. Manish Agarwalassessment Year: 2009-10 Kamal Kant Vs. Income Tax Officer Ward K-15 South Extension –One 54(1) Civic Centre Delhi New Delhi 110049 Pan No. Aaipk 1374K (Appellant) (Respondent)

Section 143(1)Section 154Section 234ASection 43(5)(d)Section 70Section 70aSection 71(2)

Kamal Kant vs. ITO Ward54(1) (v) On the facts and circumstances of the case, the learned CIT(A) erred in levying interest u/s 234A, 234 B and 234C of the Act. (vi) The appellant craves leaves to add amend alter or omit any of the above grounds

Quality Enabled Remote Solutions (P) Ltd., New Delhi vs. ITO, Ward-20(3), New Delhi

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

ITA 4107/DEL/2018[2009-10]Status: DisposedITAT Delhi17 Sept 2025AY 2009-10

Bench: Shris.Rifaur Rahman & Shri Sudhir Pareekquality Enabled Remote Solutions (P) Ltd., Vs. Ito, Ward 20 (3), Ugf – 61A, World Trade Centre, New Delhi. Babur Road, Connaught Place, New Delhi – 110 001. (Pan :Aaacq0881A) (Appellant) (Respondent) Assessee By : Shri S. Krishnan, Advocate Shri Harshit Chauhan, Advocate Revenue By : Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing : 09.07.2025 Date Of Order : 17.09.2025 O R D E R Per S.Rifaur Rahman,Am: 1. This Appeal Has Been Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-25, New Delhi [“Ld. Cit(A)”, For Short] Dated 16.08.2017 For The Assessment Year 2009-10 Raising Following Grounds Of Appeal :- “1. The Order Passed By Id. Cit(A) Is Wrong Both On Facts & In Law.

For Appellant: Shri S. Krishnan, AdvocateFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR

Section 147Section 148Section 234A

conjectures and summa rises and therefore, they deserve to be quashed. 7. The Ld. CIT(A) erred in upholding the levy of interest u/s 234A and 234B without discussing the issue in the order. 8. The order of the Ld. CIT(A) suffers from infirmity of violating principles of natural

Koshal Kishor Sharma, Jaipur vs. DCIT(Intl. Tax.) Jaipur, Jaipur

In the result, appeals of the assessee are allowed

ITA 862/JPR/2025[2015-16]Status: DisposedITAT Jaipur15 Sept 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri Shrawan Kumar Gupta, AdvFor Respondent: Shri Dharam Singh Meena, JCIT-DR

Section 147Section 148ASection 234ASection 250Section 271(1)(c)Section 69Section 69A

full. 5. The ld. AO has grossly erred in law as well as on the facts of the case in charging the interest u/s 234A, B,C. The interest so charged is being totally contrary to the provision of law and on facts of the case and hence same

Koshal Kishor Sharma, Jaipur vs. DCIT(Intl. Tax), Jaipur

In the result, appeals of the assessee are allowed

ITA 861/JPR/2025[2015-16]Status: DisposedITAT Jaipur15 Sept 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri Shrawan Kumar Gupta, AdvFor Respondent: Shri Dharam Singh Meena, JCIT-DR

Section 147Section 148ASection 234ASection 250Section 271(1)(c)Section 69Section 69A

Rajasthan Ophthalmological Society, Jaipur vs. ITO, Jaipur

In the result, the appeal of the assessee is allowed

ITA 582/JPR/2025[2018-19]Status: DisposedITAT Jaipur15 Sept 2025AY 2018-19

Bench: DR. M.L. MEENA (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Hemang Gargieya, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR a

Section 11(2)Section 11(5)Section 12ASection 139(1)Section 143(3)Section 234A

kindly be deleted in full. 3. The ld. AO erred in law as well as on the facts of the case in charging interest u/s 234A, 234B & 234C of the Act. The appellant totally denies its liability of charging of any such interest. The interest, so charged, being contrary

Ramaiah Pushpavathi, Bengaluru vs. DCIT, Circle-4(3)(1), Bengaluru

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

ITA 855/BANG/2025[2015-16]Status: DisposedITAT Bangalore15 Sept 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2015-16

For Appellant: Shri G. Venkatesh, AdvocateFor Respondent: Shri Murali Mohan, CIT DR

Section 147Section 2(47)(v)Section 234ASection 234CSection 250Section 53ASection 68

material on the facts and circumstance of the case. 14. The learned CIT(A), NFAC and Assessing Authority is not justified in levying interest u/s 234A, 234B and u/s 234C of the Act on the facts and Ramaiah Pushpavati Page 3 of 6 circumstances of the case and further

Pradeep Biharising Bundele, Jalna vs. ITO Ward-1, Jalna

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

ITA 754/PUN/2025[2012-2013]Status: DisposedITAT Pune12 Sept 2025AY 2012-2013

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Harshit Kabra (Virtual)For Respondent: Shri Shashank Ojha

Section 144Section 147Section 148Section 151Section 153CSection 234ASection 250Section 69

principles of natural justice. There is no mention in the assessment order nor in any of the notices/show cause notice regarding charging of interest u/s 234A, 234B & 234C of the I. T. Act, 1961. 6. Penalty Proceedings. Whether the learned A.O. has justified in initiating penalty proceedings u/s

Om Prakash Jaiswal, Kharagpur vs. ITO, Ward 39(2), Midnapur

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

ITA 1468/KOL/2025[2017-2018]Status: DisposedITAT Kolkata12 Sept 2025AY 2017-2018

Bench: the hearing of the appeal.”

Section 143(2)Section 234ASection 250

sustaining addition of Rs. 80,989/- as commission income which is also arbitrary as well as illegal. 6. For that the charging interest u/s 234A, 2348 & 234D amounting to Rs.15,020/-. Rs. 1,23,915/- and Rs.1,013/- which are mechanically wrong and illegal. 7. For that the appellant reserves

Manikala Vyapaar Pvt. Ltd., Kolkata vs. ITO, Ward 4(1), Kolkata

Appeal of the assessee is partly allowed

ITA 1466/KOL/2025[2018-2019]Status: DisposedITAT Kolkata12 Sept 2025AY 2018-2019

Bench: the hearing of the appeal.” 3. The issues in Ground No. 4 by the assessee is against the order of CIT(A) upholding the order of Assessing Officer, wherein the addition of Rs.33,35,000/-was made on account of unexplained cash credit under Section 68 of the Act.

Section 143(1)Section 143(2)Section 147Section 148Section 148ASection 234ASection 250Section 68

Smt. Sudha Loyalka, New Delhi vs. ITO, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 399/DEL/2017[2012-13]Status: DisposedITAT Delhi12 Sept 2025AY 2012-13

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2012-13] Smt. Sudha Loyalka, Vs Ito, Prop.Tirupati Industries, 2/1, Ward-35(2), Block-41, Singh Sabha Road, New Delhi Shakti Nagar, Delhi-110007. Pan-Aabpl6055D Appellant Respondent Appellant By Dr.Rakesh Gupta, Adv., Shri Somil Aggarwal, Adv. & Shri Deepesh Garg, Adv. Respondent By Shri Narpat Singh, Sr.Dr Date Of Hearing 24.06.2025 Date Of Pronouncement 12.09.2025 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 01.12.2016 Passed By Ld. Commissioner Of Income Tax (A)-12, New Delhi [“Ld.Cit(A)”] In Appeal No. 26/15-16 U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 18.03.2015 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2012-13. 2. Brief Facts Of The Case Are That The Assessee Is An Individual & Filed Her Return Of Income On 27.09.2012, Declaring Total Income Of Inr 3,52,180/-. The Case Of Assessee Was Selected For Scrutiny For The Reason “Large Amount Of Sundry Creditors”. Assessee Is Engaged In The Business Of Trading Of Fabrics & Readymade Garments Under The Name & Style As M/S. Tirupati Industries. The Assessee Has Shown Total Sundry Creditors Of Inr 6,77,21,342/- Which Includes Inr 3,48,88,095/- Under The Title “Retail Creditors Control Account”. In Order To Examine The Genuineness Of These Creditors, Ao Issued Notice U/S 133(6) Of The Act To 27 Parties Out Of Which Notices Issued To 20 Parities Amounting To Inr 2,78,20,495/- Were Returned Back For The Reason “Wrong Address/Incomplete Address/Non-Existed” Etc. The Ao Thereafter, Discussed Each Of The Parties To Whom Notices Were Sent & Reached To The Conclusion That These Parties Are Non-Existent & Made The Addition Of Inr 3,50,94,758/- As Bogus Creditors.

Section 133(6)Section 143(3)Section 250Section 37Section 69C

circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. AO in charging interest u/s 234A, 234B and 234C of Income Tax Act, 1961. 4. That the appellant craves the leave to add, modify, amend or delete