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“interest under section 234B”

InterestSection 234BSection 234B1,475 judgments

The decision most relied on for interest under section 234B is Godrej & Boyce Mfg. Co. Ltd. v. DCIT (328 ITR 81), cited in 1,183 judgments on BharatTax.

Leading authorities on interest under section 234B

Godrej & Boyce Mfg. Co. Ltd. v. DCIT
328 ITR 81 · 2010 · High Court
1,183
citing judgments

Rule 8D, for computing disallowance under Section 14A for expenses related to exempt income, applies from Assessment Year 2008-09 onwards; for prior years, a reasonable disallowance must be made. The disallowance under Section 14A cannot exceed the actual exempt income earned.

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.

CIT v. EKL Appliances Ltd.
345 ITR 241 · 2012 · High Court
422
citing judgments

Transfer pricing adjustments for outstanding receivables are permissible only if the Tax Officer establishes, through analysis over a period, a pattern indicating an international transaction intended to benefit an associated enterprise. The Tax Officer cannot question purely business decisions like royalty payments or exceed jurisdiction by applying cost-benefit analysis to determine the arm's length price of services.

CIT v. Cotton Naturals (I) (P.) Ltd.
55 Taxmann.com 523 · 2015 · High Court
273
citing judgments

The interest rate for benchmarking foreign currency loans advanced to Associated Enterprises should be the market-determined rate applicable to the currency of the loan, such as LIBOR for US Dollar loans, rather than a domestic lending rate like the Indian PLR.

DIT v. GE Packaged Power Inc.
373 ITR 65 · 2015 · High Court
199
citing judgments

Interest under section 234B for default in payment of advance tax is not leviable when the entire income is subject to tax deduction at source under section 195, as no advance tax liability arises for the assessee in such circumstances.

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.

DIT v. NGC Network Asia LLC
313 ITR 187 · 2009 · High Court
144
citing judgments

Where a duty is cast on the payer to deduct and pay tax at source under Section 195, the payee-assessee cannot be levied interest under Section 234B for failure to pay advance tax if the payer defaults on its TDS obligation. This principle may also extend to interest under Section 234C.

80P(2)(d) of the Act. In Kaliandas Udyag Bhavan Premises Co-op Society Ltd. v. ITO
94 Taxmann.com 15 · 2018 · ITAT
130
citing judgments

A co-operative society, even if it is a co-operative bank whose general deduction under Section 80P is restricted by Section 80P(4), can still claim a deduction under Section 80P(2)(d) for interest income derived from its investments held with another co-operative society, as it retains its identity as a co-operative society.

Judgments citing interest under section 234B

DCIT 3(2)(1), Mumbai vs. The New India Assurance Company Limited, Mumbai

The appeal of the revenue is dismissed

ITA 4634/MUM/2023[2004-05]Status: DisposedITAT Mumbai27 Oct 2025AY 2004-05

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Respondent: Shri Farrokh V. Irani, Adv. &
Section 143(3)Section 250Section 263Section 271(1)(c)Section 44

accounted in F.Y. 2003-04, (ii) Balance amount of provisions not allowed in earlier years and paid during the P.Y., and (iii) Interest under section 234B & C disallowed in earlier year now credited to P&L account due to waiver. From the findings of Tribunal while confirming the disallowances / additions

Addl CIT Sp RG 22, Mumbai vs. Dsp Merrill Lynch Ltd, Mumbai

In the result, appeal of the assessee is partly allowed and the appeal of the revenue is dismissed

ITA 2198/MUM/2011[1994-95]Status: DisposedITAT Mumbai27 Oct 2025AY 1994-95

Bench: Shri Amit Shukla, Jm& Ms Padmavathy S, Am

For Appellant: Shri Nitesh JoshiFor Respondent: Shri. Leyaqat Ali Aafaqui, Sr. AR
Section 140ASection 143(1)(a)Section 143(3)Section 147Section 234Section 234BSection 234B(3)Section 250Section 80Section 800

Ground 4(a) above, and subject to any relief being granted in the present appeal on various issues, the appellant submits that interest under section 234B of the Act ought to be levied only for the period from the date of passing of Intimation under section ... Without prejudice to grounds 4(a) and 4(b) above, the appellant submits that in the event the levy of interest under section 234B is upheld, while computing interest chargeable under section 2348, the tax paid u/s 140A should be adjusted first against the tax liability and then against

Dsp Merrill Lynch Limited, Mumbai vs. Addl C.I.T. Range 4(1), Mumbai

In the result, appeal of the assessee is partly allowed and the appeal of the revenue is dismissed

ITA 1581/MUM/2011[1994-95]Status: DisposedITAT Mumbai27 Oct 2025AY 1994-95

Bench: Shri Amit Shukla, Jm& Ms Padmavathy S, Am

For Appellant: Shri Nitesh JoshiFor Respondent: Shri. Leyaqat Ali Aafaqui, Sr. AR
Section 140ASection 143(1)(a)Section 143(3)Section 147Section 234Section 234BSection 234B(3)Section 250Section 80Section 800

Ground 4(a) above, and subject to any relief being granted in the present appeal on various issues, the appellant submits that interest under section 234B of the Act ought to be levied only for the period from the date of passing of Intimation under section ... Without prejudice to grounds 4(a) and 4(b) above, the appellant submits that in the event the levy of interest under section 234B is upheld, while computing interest chargeable under section 2348, the tax paid u/s 140A should be adjusted first against the tax liability and then against

Care Today Fund, New Delhi vs. ITO Ward Exemption 1(3), Civic Centre New Delhi

In the result, the appeal of assessee is allowed

ITA 5734/DEL/2024[2017-18]Status: DisposedITAT Delhi27 Oct 2025AY 2017-18

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2017-18 Care Today Fund, Vs. Income Tax Officer, F-26, First Floor, Exemption 1(3), Connaught Place, New Delhi New Delhi-1100 01 Pan :Aaatc3762B (Appellant) (Respondent)

Section 11Section 11(2)Section 11(3)Section 12ASection 142(1)Section 143(2)Section 2(15)Section 250Section 80G(5)(vi)

Income Tax Act 1961. 3. That the learned Assessing Officer has erred both in law and on facts in levying interest under section 234B of the Act which interest is not loveable on the facts and circumstances of the case of the appellant”. 6. Learned Authorized Representative for the appellant/assessee

Dress Code, Bengaluru vs. Income Tax Officer, Ward-5(2)(1), Bangalore

In the result, the appeal of the assessee is allowed

ITA 1650/BANG/2025[2018-19]Status: DisposedITAT Bangalore22 Oct 2025AY 2018-19

Bench: Shri Prashant Maharishiassessment Year : 2018-19

For Appellant: Shri B.R. Sudheendra, AdvocateFor Respondent: Shri Ganesh R. Ghale, Standing Counsel for the Revenue
Section 143(3)Section 144BSection 234ASection 234BSection 69C

234A is not leviable. The appellant denies its liability to pay interest under section 234A. 12. The learned AO has erred in levying interest under section 234B of the Act. On the facts and circumstances of the case and law applicable, interest under sections 234B is not leviable. The appellant ... denies its liability to pay interest under section 234B. Prayer 13. In view of the above and other grounds to be adduced at the time of hearing, the Appellant prays that the order passed by the learned AO as well as the learned CIT(A) be quashed

DCIT, Central Circle-8(1), Mumbai vs. The Estate Investment Company Pvt Ltd, Mumbai

3012/Mum/2025

ITA 3936/MUM/2025[2017-18]Status: DisposedITAT Mumbai17 Oct 2025AY 2017-18
Section 132Section 132(4)Section 69A

seized from the Appellants premises and uncorroborated evidence. The Appellants pray that the same be deleted. 3. The Ld. AO erred in levying interest under section 234B and 234C of the Act. The Appellant prays that the interest under section 234B and 234C of the Act be deleted or consequentially ... seized from the Appellants premises and uncorroborated evidence .The Appellants pray that the same be deleted. 4. The Ld. AO erred in levying interest under section 234B and 234C of the Act. The Appellant prays that the interest under section 234B and 234C of the Act be deleted or consequentially

DCIT, Central Circle-8(1), Mumbai vs. The Estate Investment Company Pvt Ltd, Mumbai

ITA 3928/MUM/2025[2015-16]Status: DisposedITAT Mumbai17 Oct 2025AY 2015-16
Section 132Section 132(4)Section 69A

seized from the Appellants premises and uncorroborated evidence. The Appellants pray that the same be deleted. 3. The Ld. AO erred in levying interest under section 234B and 234C of the Act. The Appellant prays that the interest under section 234B and 234C of the Act be deleted or consequentially ... seized from the Appellants premises and uncorroborated evidence .The Appellants pray that the same be deleted. 4. The Ld. AO erred in levying interest under section 234B and 234C of the Act. The Appellant prays that the interest under section 234B and 234C of the Act be deleted or consequentially

The Estate Investment Company Private Limited, Mumbai vs. DCIT Central Circle 8(1), Mumbai

ITA 3228/MUM/2025[2015-16]Status: DisposedITAT Mumbai17 Oct 2025AY 2015-16
Section 132Section 132(4)Section 69A

seized from the Appellants premises and uncorroborated evidence. The Appellants pray that the same be deleted. 3. The Ld. AO erred in levying interest under section 234B and 234C of the Act. The Appellant prays that the interest under section 234B and 234C of the Act be deleted or consequentially ... seized from the Appellants premises and uncorroborated evidence .The Appellants pray that the same be deleted. 4. The Ld. AO erred in levying interest under section 234B and 234C of the Act. The Appellant prays that the interest under section 234B and 234C of the Act be deleted or consequentially

The Estate Investment Company Private Limited, Mumbai vs. DCIT Central Circle 8(1), Mumbai

3012/Mum/2025

ITA 3227/MUM/2025[2017-18]Status: DisposedITAT Mumbai17 Oct 2025AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 132Section 132(4)Section 69A

seized from the Appellants premises and uncorroborated evidence. The Appellants pray that the same be deleted. 3. The Ld. AO erred in levying interest under section 234B and 234C of the Act. The Appellant prays that the interest under section 234B and 234C of the Act be deleted or consequentially ... seized from the Appellants premises and uncorroborated evidence .The Appellants pray that the same be deleted. 4. The Ld. AO erred in levying interest under section 234B and 234C of the Act. The Appellant prays that the interest under section 234B and 234C of the Act be deleted or consequentially

The Estate Investment Company Private Limited, Mumbai vs. DCIT Central Circle 8(1), Mumbai

ITA 3225/MUM/2025[2019-20]Status: DisposedITAT Mumbai17 Oct 2025AY 2019-20
Section 132Section 132(4)Section 69A

seized from the Appellants premises and uncorroborated evidence. The Appellants pray that the same be deleted. 3. The Ld. AO erred in levying interest under section 234B and 234C of the Act. The Appellant prays that the interest under section 234B and 234C of the Act be deleted or consequentially ... seized from the Appellants premises and uncorroborated evidence .The Appellants pray that the same be deleted. 4. The Ld. AO erred in levying interest under section 234B and 234C of the Act. The Appellant prays that the interest under section 234B and 234C of the Act be deleted or consequentially

The Estate Investment Company Private Limited, Mumbai vs. DCIT Central Circle 8(1), Mumbai

3012/Mum/2025

ITA 3224/MUM/2025[2020-21]Status: DisposedITAT Mumbai17 Oct 2025AY 2020-21
Section 132Section 132(4)Section 69A

seized from the Appellants premises and uncorroborated evidence. The Appellants pray that the same be deleted. 3. The Ld. AO erred in levying interest under section 234B and 234C of the Act. The Appellant prays that the interest under section 234B and 234C of the Act be deleted or consequentially ... seized from the Appellants premises and uncorroborated evidence .The Appellants pray that the same be deleted. 4. The Ld. AO erred in levying interest under section 234B and 234C of the Act. The Appellant prays that the interest under section 234B and 234C of the Act be deleted or consequentially

The Estate Investment Company Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

3012/Mum/2025

ITA 3223/MUM/2025[2021-22]Status: DisposedITAT Mumbai17 Oct 2025AY 2021-22
Section 132Section 132(4)Section 69A

seized from the Appellants premises and uncorroborated evidence. The Appellants pray that the same be deleted. 3. The Ld. AO erred in levying interest under section 234B and 234C of the Act. The Appellant prays that the interest under section 234B and 234C of the Act be deleted or consequentially ... seized from the Appellants premises and uncorroborated evidence .The Appellants pray that the same be deleted. 4. The Ld. AO erred in levying interest under section 234B and 234C of the Act. The Appellant prays that the interest under section 234B and 234C of the Act be deleted or consequentially

The Estate Investment Company Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

3012/Mum/2025

ITA 3222/MUM/2025[2022-23]Status: DisposedITAT Mumbai17 Oct 2025AY 2022-23
Section 132Section 132(4)Section 69A

seized from the Appellants premises and uncorroborated evidence. The Appellants pray that the same be deleted. 3. The Ld. AO erred in levying interest under section 234B and 234C of the Act. The Appellant prays that the interest under section 234B and 234C of the Act be deleted or consequentially ... seized from the Appellants premises and uncorroborated evidence .The Appellants pray that the same be deleted. 4. The Ld. AO erred in levying interest under section 234B and 234C of the Act. The Appellant prays that the interest under section 234B and 234C of the Act be deleted or consequentially

DCIT Central Circle-8(1), Mumbai vs. The Estate Investment Company Private Limited, Mumbai

3012/Mum/2025

ITA 3087/MUM/2025[2016-17]Status: DisposedITAT Mumbai17 Oct 2025AY 2016-17
Section 132Section 132(4)Section 69A

seized from the Appellants premises and uncorroborated evidence. The Appellants pray that the same be deleted. 3. The Ld. AO erred in levying interest under section 234B and 234C of the Act. The Appellant prays that the interest under section 234B and 234C of the Act be deleted or consequentially ... seized from the Appellants premises and uncorroborated evidence .The Appellants pray that the same be deleted. 4. The Ld. AO erred in levying interest under section 234B and 234C of the Act. The Appellant prays that the interest under section 234B and 234C of the Act be deleted or consequentially

The Estate Investment Company Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

ITA 3012/MUM/2025[2014-15]Status: DisposedITAT Mumbai17 Oct 2025AY 2014-15
Section 132Section 132(4)Section 69A

seized from the Appellants premises and uncorroborated evidence. The Appellants pray that the same be deleted. 3. The Ld. AO erred in levying interest under section 234B and 234C of the Act. The Appellant prays that the interest under section 234B and 234C of the Act be deleted or consequentially ... seized from the Appellants premises and uncorroborated evidence .The Appellants pray that the same be deleted. 4. The Ld. AO erred in levying interest under section 234B and 234C of the Act. The Appellant prays that the interest under section 234B and 234C of the Act be deleted or consequentially

Anand Krishi Kendra, Badnera vs. ITO Ward-4, Amravati

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

ITA 491/NAG/2025[2017-18]Status: DisposedITAT Nagpur16 Oct 2025AY 2017-18

Bench: Shri Pavan Kumar Gadaleanand Krishi Kendra Athwadi Bazar, New Town Badnera, Amravati 444607, ……………. Appellant Maharashtra. Pan – Aabfa8196Q V/S Income Tax Officer ……………. Respondent Ward–4, Amravati-444701, Maharashtra. Assessee By: Shri.Mahavir Atal, A.R. Revenue By : Shri Surjit Kumar Saha.Sr.Dr

For Appellant: Shri.Mahavir Atal, A.RFor Respondent: Shri Surjit Kumar Saha.Sr.DR
Section 234B

money invested as unexplained when the source of the same is accepted by him. 5. The appellant denies his liability to pay interest under Section 234B and 234C without prejudice to levy of interest under Section 234B and 234C are unjustified & bad in law. 6. The appellant craves

Himalaya Realestate Private Limited, Shakti Nagar vs. Assistant Commissioner of Income Tax Circle 11(2), Delhi, Cr Building

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

ITA 3426/DEL/2024[2017-18]Status: DisposedITAT Delhi15 Oct 2025AY 2017-18

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2017-18 Himalaya Realestate Private Vs. Assistant Commissioner Of Income Limited, 7365, Shakti Nagar, Tax, Circle 11(2), Delhi – 1100 07 Delhi Pin: 1100 02 Pan :Aacch6225K (Appellant) (Respondent)

Section 143(2)Section 143(3)Section 234BSection 234CSection 250Section 271ASection 68

circumstances of the case and in law, the Hon'ble CIT(A) grossly erred in upholding the order of Ld. AO in charging interest under Section 234B and Section 234C of the Act; 9. That the penalty proceedings initiated under Section 271AAC of the Act is incorrect, illegal

Franklin Templeton Internaitoanl Services (I) P.Ltd, Mumbai vs. DCIT (OSD) 3(1), Mumbai

In the result the appeal filed by the assessee for assessment year 2007-08 and 2008-09 stands partly allowed

ITA 7216/MUM/2012[2008-09]Status: DisposedITAT Mumbai13 Oct 2025AY 2008-09

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 133(6)Section 92D

block of assets, as a consequence to and consistent with such assessment orders. Ground III - Levy of interest under Section 234B of Rs.69,54,567 and 234D of Rs.1,42,024 of the Act 1. On the facts and in the circumstances of the case, the learned AO has erred ... levying interest under Section 234B of the Act of Rs.69,54,567 and under Section 234D of the Act of Rs. 1,42,024. The Appellant prays that the AO be directed to grant consequential relief in computing interest under Section 234B and Section 234D of the Act in accordance

Franklin Templeton International Services (I) P. Ltd, Mumbai vs. Asst CIT 3(1)(OSD), Mumbai

In the result the appeal filed by the assessee for assessment year 2007-08 and 2008-09 stands partly allowed

ITA 6986/MUM/2011[2007-08]Status: DisposedITAT Mumbai13 Oct 2025AY 2007-08

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 133(6)Section 92D

block of assets, as a consequence to and consistent with such assessment orders. Ground III - Levy of interest under Section 234B of Rs.69,54,567 and 234D of Rs.1,42,024 of the Act 1. On the facts and in the circumstances of the case, the learned AO has erred ... levying interest under Section 234B of the Act of Rs.69,54,567 and under Section 234D of the Act of Rs. 1,42,024. The Appellant prays that the AO be directed to grant consequential relief in computing interest under Section 234B and Section 234D of the Act in accordance

Assistant Commissioner of Income Tax, Kautilya Bhavan, Bkc, Mumbai vs. Tata Education Trust, Mumbai

In the result, Revenue’s appeal is dismissed

ITA 4852/MUM/2024[2013-14]Status: DisposedITAT Mumbai10 Oct 2025AY 2013-14

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w ShriFor Respondent: Shri Ritesh Mishra, CIT DR
Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

facts and under the circumstances of the case and in law, the Ld. CIT(A) erred in upholding levy of interest under section 234B and 234C of the Act on the additions not envisaged by the Appellant. 5. On the facts and under the circumstances of the case ... clubbing the deduction u/s 80G and 80GGA ought to have been allowed. 7. The Id. CIT(A) erred in upholding levy of interest under section 234B of the Act for the addition not envisaged by the Appellant.” 53. Ground Nos. 1 to 4 are identical to Ground