“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

Ranjan Sharma, New Delhi vs. DCIT, Central Circle -31, New Delhi

In the result, the appeal of the assessee is allowed

ITA 1489/DEL/2024[2021-22]Status: DisposedITAT Delhi30 May 2025AY 2021-22

Bench: Ms. Madhumita Roy & Shri Khettra Mohan Roy[Assessment Year 2021-22]

Section 115BSection 143(2)Section 143(3)Section 153A(1)Section 153CSection 153DSection 234ASection 69

case, Ld. CIT(A) has erred in law and on facts in not reversing the action of Ld. Assessing Officer in charging the interest u/s 234A, 234B and 234C of the Income Tax Act, 1961.” 3. The sole ground of adjudication is whether the addition is not sustainable u/s

Ajay Kumar, Ghaziabad vs. Pr. CIT (Central), Meerut

In the result, appeal of the assessee is dismissed

ITA 733/DEL/2021[2016-17]Status: DisposedITAT Delhi30 May 2025AY 2016-17

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 143(2)Section 143(3)Section 263

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’: NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI AVDHESH

Dawoodi Bohra Jamat, Udaipur vs. ITO Ward Exemption Udaipur, Udaipur

In the result, appeal of the assessee is allowed

ITA 425/JODH/2025[2014-15]Status: DisposedITAT Jodhpur29 May 2025AY 2014-15

Bench: DR. MITHA LAL MEENA (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

Section 142(1)Section 143(2)Section 144Section 147Section 148Section 69

full. 4. 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

Naresh Kumar Sewak, Dungarpur vs. Income Tax Officers, Ward Dungarpur, Dungarpur

In the result, the appeal of the assesee is allowed for statistical purposes pronounced under Rule 34(4) of the Income Tax (Appellate Tribunal)

ITA 125/JODH/2025[2017-18]Status: DisposedITAT Jodhpur28 May 2025AY 2017-18

Bench: DR MITHA LAL MEENA (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Shrawan Kumar, AdvocateFor Respondent: Shri Karni Dan, Addl. CIT-DR

Section 115BSection 144Section 147Section 234ASection 69A

deleted in full. 5. The 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

Fidelity Information Services India Private Limited, Punjab vs. Deputy Commissioner of Income Tax, Chandigarh

In the result, the appeal of the Revenue is dismissed

ITA 998/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh28 May 2025AY 2020-21

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 998/Chd/2024 निर्धारण वर्ष / Assessment Year: 2020-21 Fidelity Information Services Vs The Dcit, Chandigarh, India Private Ltd., 2Nd A-45, Industrial Area, Sector 74, Phase 8B, Sas Nagar. स्थायी लेखा सं./Pan No: Aagcs0395D अपीलार्थी/Appellant प्रत्यर्थी/Respondent Assessee By: Shri Vishal Kalra, Advocate & Ms. Sumisha, Ca Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 06.05.2025 Date Of Pronouncement : 28.05.2025 Hybrid Hearing Order Per Raj Pal Yadav, Vp The Assessee Is In Appeal Before The Tribunal Against The Assessment Order Dated 31.07.2024 Passed U/S 143(3) Read With Section 144C(13)/144B Of The Income Tax Act In

For Appellant: Shri Vishal Kalra, Advocate & Ms. Sumisha, CAFor Respondent: Shri Manav Bansal, CIT DR

Section 139(1)Section 143(2)Section 143(3)Section 144C(13)Section 234ASection 270A

call for recording of any finding. Hence rejected. 3. In Ground No.3 assessee has pleaded that ld. AO has erred in charging interest u/s 234A of the Income Tax Act. The ld. counsel for the assessee placed on record copy of a Notification dated 31.12.2020 and submitted that due date ... enhanced. The assessee has filed such return well within due date provided u/s 139(1) in view of this Notification, hence interest u/s 234A is not chargeable upon the assessee. This issue has not been adjudicated by the AO, therefore, we deem it appropriate to set aside this issue

Mohammad Mohsin Qureshi, Mumbai vs. Assessing Officer, Mumbai

In the result, the grounds of appeal raised by assessee is partly allowed

ITA 4218/MUM/2024[2018-19]Status: DisposedITAT Mumbai28 May 2025AY 2018-19

Bench: Shri Pawan Singh(Physical Hearing) Mohammad Mohsin Qureshi Ito Ward-42(2)(4) Room No. 375, Plot No. 2, Shashtri Vs Kautilya Bhavan, Maharashtra. Nagar, Near Bus Depot, Bandra West, Maharashtra-400050. [Pan No. Bexpk0365Q Appellant / Assessee Respondent / Revenue Assessee By Shri Vimal Punmiya Ca Revenue By Ms. Pradnya Gholap, Sr. Dr Date Of Institution Of Appeal 21.08.2024 Date Of Hearing 15.04.2025 Date Of Pronouncement 28.05.2025 Order Under Section 254(1) Of Income Tax Act

Section 234ASection 254(1)Section 270ASection 272A(1)(d)Section 56(2)Section 56(2)(x)

providing sufficient opportunity of being heard. 3. On the facts and circumstances of the case and in law, Hon. CIT erred in levying interest u/s 234A, 234B and 234C of the Income Tax Act, 1961. 4.On the facts and circumstances of case and in law, Hon. CIT erred in initiating

Roots Developers Pvt. Ltd., New Delhi vs. DCIT Circle-03, Gurgaon

In the result, the appeal of the assessee is allowed

ITA 1685/DEL/2019[2015-16]Status: DisposedITAT Delhi28 May 2025AY 2015-16

Bench: Sh. Sudhir Kumar

Section 142(1)Section 143(2)Section 143(3)Section 234A

erred in law and on facts of the case in not reversing the action of Ld. AO in charging interest u/s 234A, 234B and 234C of the Act.” 3. The brief facts of the case are that the assessee e-filed the return of income declaring total income

Akshat Loyalka, Jaipur vs. Rjn-C-(101)(1), Jaipur

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

ITA 1019/JPR/2024[2016-17]Status: DisposedITAT Jaipur27 May 2025AY 2016-17

For Appellant: Shri Mahendra Gargieya, Advocate &For Respondent: Shri Gautam Singh Choudhary, Addl. CIT-DR

Section 144BSection 147Section 234ASection 250Section 5Section 69A

full. 5. The ld. CIT(A) erred in law as well as in facts of the case in confirming the levy of interest u/s 234A, 234B, 234C& 234D of the Act. The levy interest being charged, is contrary to the provisions of law and facts, kindly be deleted in full

Deepak Kumar Chaturvedi, Mumbai vs. Addl/JCIT, Mumbai

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

ITA 642/MUM/2025[2017-2018]Status: DisposedITAT Mumbai27 May 2025AY 2017-2018

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2017-18 Deepak Kumar Chaturvedi Addl/Jcit Ito Ward A-5/502, Jyoti Complex, Film 42(2)(2), City Road, Goregaon East, Kautilya Bhavan, Bkc, Vs. Mumbai 400063. Bandra (E), Mumbai 400001. Pan: Abipc6521D (Appellant) (Respondent) Present For: Assessee : Shri. Mahesh Saboo, Ca Revenue : Shri. Rajesh Meshram, Sr. Dr Date Of Hearing : 24.03.2025 Date Of Pronouncement : 27.05.2025

For Appellant: Shri. Mahesh Saboo, CAFor Respondent: Shri. Rajesh Meshram, Sr. DR

Section 10Section 143(1)Section 234ASection 271(1)(c)

IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT

Sanjeev Kumar Garg, New Delhi vs. DCIT, Central Circle 20, Delhi

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

ITA 130/DEL/2023[2019-20]Status: DisposedITAT Delhi27 May 2025AY 2019-20

Bench: Shri Yogesh Kumar Us & Shri Brajesh Kumar Singh[Assessment Year: 2019-20]

Section 115BSection 131Section 143(3)Section 153ASection 271ASection 69A

assessee and as per law. Ground no.1 and 2 are allowed for statistical purposes. 10. Ground no.3 relates to charging of interest u/s 234A (Rs.23,765/- and 234B (Rs.5,93,875/-) of the Act. The assessee submitted that interest u/s 234A of the Act amounting to Rs.23,761/- was wrong ... written submission of the assessee in para no.5 to 6 of another written submission is reproduced as under:- B) Charging of interest u/s 234A and 234B 5. That the Assessing Officer has erred in not allowing credit as self assessment tax paid for Rs.3080000/- seized by the Department inspite

Ashiana Buildprop Private Limited, Udaipur vs. DCIT, Central Circle-1, Udiapur, Udaipur

ITA 709/JODH/2024[2016-17]Status: DisposedITAT Jodhpur26 May 2025AY 2016-17

Bench: DR. MITHA LAL MEENA (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

Section 132Section 145(3)Section 153ASection 234ASection 250

deleted in full. 4. The ld. AO has grossly erred in law as well as on thefacts of the case in charging the interest u/s 234A, B,C and D. The interest so charged is being totally contrary to the provision of law and on facts of the case ... deleted in full. 4. The ld. AO has grossly erred in law as well as on thefacts of the case in charging the interest u/s 234A, B,C and D. The interest so charged is being totally contrary to the provision of law and on facts of the case

Ashiana Buildprop Private Limited, Udaipur vs. DCIT, Central Circle-1 Udaipur, Udaipur

ITA 708/JODH/2024[2015-16]Status: DisposedITAT Jodhpur26 May 2025AY 2015-16

Section 132Section 145(3)Section 153ASection 234ASection 250

Ashiana Buildprop Private Limited, Udaipur vs. DCIT- Central Circle-1 Udiapur, Udaipue

ITA 707/JODH/2024[2014-15]Status: DisposedITAT Jodhpur26 May 2025AY 2014-15

Section 132Section 145(3)Section 153ASection 234ASection 250

Ashiana Buildprop Private Limited, Udaipur vs. DCIT, Central Circle-1, Udaipur

ITA 706/JODH/2024[2013-14]Status: DisposedITAT Jodhpur26 May 2025AY 2013-14

Section 132Section 145(3)Section 153ASection 234ASection 250

Hardeep Dalal, Sonepat vs. ITO Ward 35(5), New Delhi

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

ITA 3430/DEL/2023[2017-18]Status: DisposedITAT Delhi23 May 2025AY 2017-18

Bench: Shris.Rifaur Rahman

For Appellant: Shri Shivam Gupta, CAFor Respondent: Shri Sanjay Kumar, Sr. DR

Section 143(1)Section 250Section 68

learned Commissioner of Income Tax (Appeals) and learned Assessing Officer of Income Tax has erred both in law and on facts in levying interest u/s 234A, section 234B & section 234D of the Act, which interest is not leviable on the facts and circumstances of the case of the appellant

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)

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.7,81,772.00 and U/s 234C Rs.1,59,618.00 Total amount is Rs,11,02,191.00 this interest amount

Shilpa Rakeshbhai Sheth, Ahmedabad vs. The ITO, Ward-3(3)(5), Ahmedabad

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

ITA 1863/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad21 May 2025AY 2014-15

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year 2014-15

For Appellant: Shri Divyang Shah, A.RFor Respondent: Shri Kamlesh Makwana, CIT-D.R

Section 143(3)Section 147Section 148Section 234ASection 68Section 69A

Whether, on facts and in circumstances of the case and in law, Ld CIT(A) has erred in confirming the interest u/s 234A of the act? 4. Whether, on facts and in circumstances of the case and in law, Ld. AO erred in issuing notice u/s

Mixpanel, Inc., San Francisco vs. Assistant Commissioner of Income Tax, Circle 2(2)(1), International Tax, New Delhi

The appeal is allowed

ITA 1605/DEL/2025[2022-23]Status: DisposedITAT Delhi21 May 2025AY 2022-23

Bench: SHRI ANUBHAV SHARMA (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

For Appellant: Shri Nishank Vashistha, Advocate &For Respondent: Shri Abhishek Sharma, CIT-DR

Section 143Section 143(3)Section 144Section 144CSection 153Section 234ASection 270ASection 274

facts and circumstances of the case and in law, the Learned AO has erred in charging interest u/s 234A, 234B, 234C & 234D, as applicable. 5. On the facts and circumstances of the case and in law, the Ld. AO has erred in computing the total tax liability without considering

Aksh Optifibre Limited, New Delhi vs. ACIT, Circle - 2, Alwar

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

ITA 170/JPR/2024[2010-11]Status: DisposedITAT Jaipur20 May 2025AY 2010-11

For Appellant: Shri Akul Agarwal, C.A. (thr. V.C.)For Respondent: Shri Arvind Kumar, CIT-DR

Section 143(3)Section 147Section 148Section 156Section 234ASection 250

circumstances of the case, CIT(A) has erred in law and on facts in confirming the action of the Ld. A.O. In charging interest u/s 234A, 234B, 234C and 234D more so when such interest could not be levied under the law. 7. That the appellant craves the leave

Vinod Omprakash Kainya, Mumbai vs. Assistant Commissioner of Income Tax, Circle 25(1), Mumbai

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

ITA 6429/MUM/2024[2009-2010]Status: DisposedITAT Mumbai20 May 2025AY 2009-2010

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2009-10 Vinod Omprakash Kainya, Asst. Cit Circle-25(1), Flat No. 41/42, Minal Apartment, Room No. 402, 4Th Floor, C-10, Juhu Tara Road, Santacruz West, Vs. Pratyaksh Kar Bhavan, Bkc, Mumbai-400054. Bandra East, Mumbai-400051. Pan No. Aglpk 1448 D Appellant Respondent

For Appellant: Mr. Sachin SarawagiFor Respondent: Ms. Kavita P. Kaushik, Sr. DR

Section 133(6)Section 143(1)Section 148Section 234ASection 271

cancelled 4. On the facts and in the circumstances of the case and in law, the Learned Assessing Officer erred in charging Interest u/s 234A, 234B & 234C arbitrarily 5 On the facts and in the circumstances of the case and in law, the Learned Assessing Officer erred in initiating penalty