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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

J P Morgan Services India Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 2(2)(1), Mumbai

In the result, assessee’s appeal is allowed

ITA 4781/MUM/2024[2020-21]Status: DisposedITAT Mumbai30 Sept 2025AY 2020-21

Bench: Shri Beena Pillai & Smt. Renu Jauhrij P Morgan Services India Vs. Deputy Commissioner Of Private Limited (‘The Income-Tax, Circle 2(2)(1) Appellant’) Aayakar Bhawan, Tower A Blk 9, Tower B Blk Maharishi Karve Road, 10, Tower C Blk 11, Nirlon New Marine Lines, Knowledge Park, Western Churchgate, Express Highway, Goregaon Mumbai-400020. East, Mumbai Suburban, 400063. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabcd0503B Appellant .. Respondent

For Appellant: Shri Fenil BhattFor Respondent: Ms. Neena Jeph (CIT DR)
Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 153Section 92D

facts and in the circumstances of the case, the Ld.AO has erred in levying interest under section 234B of the Act amounting to Rs. 77,86,88,560. 16. On the facts and in the circumstances of the case and in law, the Ld. AO has erred in initiating penalty

Shell International Petroleum Company Limited, Mumbai vs. Deputy Commissioner of Income Tax International Taxation -4(2)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 4712/MUM/2023[2021-22]Status: DisposedITAT Mumbai30 Sept 2025AY 2021-22

Bench: Smt. Beena Pillai & Smt. Renu Jauhrishell International Dy. Commissioner Of Petroleum Company Income –Tax (International Limited Taxation) 4(2)(1), Mumbai C/O B S R & Co. Llp, 2Nd 17Th Floor, Room No. 1708, Air Vs. Floor, Lodha Excelus, India Building, Nariman Point, Apollo Mills Compound, Mumbai N.M. Joshi Marg, Mahalakshmi, Mumbai 400011 स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaics0357B (Appellant) (Respondent) निर्ााररतीकीओरसे/ Assessee By: Shri. Madhur Agrawal/ Ms. Reema Grewal /Revenue By: Shri Satya Pal Kumar Cit (Dr) Date Of Hearing 06.08.2025 Date Of Pronouncement 30.09.2025 आदेश/O R D E R Per Renu Jauhri [A.M]: This Appeal Is Filed By The Assessee Against The Order Of Dy. Cit (It), Mumbai Dated 27.09.2023 Passed As Per The Directions Of The Dispute Resolution Panel (Drp) U/S. 144C(5) Of The Income Tax Act, 1961 [Hereinafter Referred To As "Act"] For Assessment Year [A.Y.] 2021-22. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri. Madhur Agrawal/For Respondent: Shri Satya Pal Kumar CIT (DR)
Section 143(3)Section 144C(13)Section 144C(5)Section 153Section 2(24)Section 9(1)(vi)

Erred in levying interest under section 234A of the Act without appreciating the facts and circumstance of the case. Interest under section 234B of the Act 15. Erred in levying interest under section 234B of the Act without appreciating the facts and circumstance of the cate

Digicert Inc., United States vs. ACIT, Circle Int. Taxation 1(2)(2), Delhi

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

ITA 1177/DEL/2025[2022-23]Status: DisposedITAT Delhi30 Sept 2025AY 2022-23

Bench: Shri M. Balaganesh & Shri Vimal Kumardigicert Inc, Vs. Acit, 2600, West Executive Pkwy, Income Tax Officer, Suite 500, Lehi, Utah, Foreign, Circle Int. Taxation,- United States, Utah 1(2)(2), New Delhi (Appellant) (Respondent) Pan: Aaecd9837H Assessee By : Ms. Tanmayee, Adv Revenue By: Shri. M.S. Nethrapal, Cit Dr Date Of Hearing 17/09/2025 Date Of Pronouncement 30/09/2025

For Appellant: Ms. Tanmayee, AdvFor Respondent: Shri. M.S. Nethrapal, CIT DR
Section 143(3)Section 144C(1)Section 144C(13)Section 144C(5)Section 9(1)(vii)

raised by the assessee are allowed. 6. The Ground No. 7 raised by the assessee is regarding the chargeability of interest under section 234B of the Act which would be consequential in nature. 7. The Ground No. 8 raised by the assessee is challenging the initiation of penalty proceedings under

Maimoon Fashion Accessories Private Limited, Mumbai vs. Income Tax Officer, Ward 7(2)(1), Mumbai

In the result, the appeal by the assessee is allowed

ITA 5010/MUM/2025[2016-17]Status: DisposedITAT Mumbai26 Sept 2025AY 2016-17

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhailmaimoon Fashion Accessories Pvt. Ltd., 645, Maimoon House, Mohili Village, A.K. Road, J.B. Nagar S.O., Mumbai – 400059 ............... Appellant Pan : Aaccm3307P

For Appellant: Ms. Rupal KakuFor Respondent: Shri Rajiv Kadam, Sr.DR
Section 2(47)Section 2(47)(ii)Section 250Section 271(1)(c)Section 45

ground is consequential in nature and will not survive if the addition on account of capital gains is deleted. Ground 5: Levy of interest under sections 234B 1. This ground is consequential in nature and will not survive if the addition on account of capital gains is deleted ... open. 17. Grounds No.4 and 5 raised in assessee’s appeal pertaining to set off of loss of current year and levy of interest under section 234B of the Act are consequential in nature and therefore, do not need any separate adjudication. 18. In the result, the appeal

Lotus Footwear Enterprises Limited-India Branch, Tiruvannamalai vs. DCIT, International Tax 1(2), Chennai

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

ITA 800/CHNY/2022[2019-2020]Status: DisposedITAT Chennai25 Sept 2025AY 2019-2020

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

For Appellant: Shri. Sriram Seshadri, C.A. &For Respondent: Ms. Pavuna Sundari, C.I.T
Section 10A

disclosed in the return of income of the Appellant. V. Consequential Relief 13. The respondent erred in charging interest under Section 234B of the Act which is consequential in nature. The grounds of appeal raised by the Appellant herein are without prejudice to each other. The Appellant craves leave

Lotus Footwear Enterprises Limited-India Branch, Tiruvannamalai vs. DCIT, International Tax 1(2), Chennai

ITA 799/CHNY/2022[2018-2019]Status: DisposedITAT Chennai25 Sept 2025AY 2018-2019

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपील सं./It(Tp)A No.: 20/Chny/2021 &

Section 10ASection 115J

disclosed in the return of income of the Appellant. V. Consequential Relief 13. The respondent erred in charging interest under Section 234B of the Act which is consequential in nature. The grounds of appeal raised by the Appellant herein are without prejudice to each other. The Appellant craves leave

Lotus Footwear Enterprises Limited-India Branch, Tiruvannamalai vs. DCIT, International Tax 1(2), Chennai

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

ITA 798/CHNY/2022[2017-2018]Status: DisposedITAT Chennai25 Sept 2025AY 2017-2018

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

For Appellant: Shri. Sriram Seshadri, C.A. &
Section 10A

disclosed in the return of income of the Appellant. V. Consequential Relief 13. The respondent erred in charging interest under Section 234B of the Act which is consequential in nature. The grounds of appeal raised by the Appellant herein are without prejudice to each other. The Appellant craves leave

Queen Merchandise Private Ltd, Surat vs. DCIT Central Circle 5(2), Mumbai

ITA 3687/MUM/2025[2021-22]Status: DisposedITAT Mumbai25 Sept 2025AY 2021-22

Bench: Shri Pawan Singh (Jm) & Shri Omkareshwar Chidara (Am) Queen Merchandise Pvt. Ltd. Dcit, Cc-5(2) Office No. 102, 1St Floor Room No. 427 S.Y. No. 1105-1107, Tulsi Vs. Kautilya Bhavan Building, Mahidharpura C-41 To C-43, G Somnath Mahadev Ni Sheri Block, Bck, Bandra Surat, Gujarat-395 003. Mumbai-400 051. Pan : Aaacq4048F Appellant Respondent

For Appellant: Shri Annavaran KosuriFor Respondent: Shri Himanshu Gandhi, CA
Section 143(3)Section 145(3)Section 234BSection 270A

circumstances of the case and in law, the Ld. CIT(A) erred in confirming the action of Ld. AO in charging interest under section 234B of the I.T. Act, 1961. 9. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred

Sangeet Gupta, Satna vs. Income Tax Officer Ward-1, Satna

In the result, the appeal is allowed for statistical purposes

ITA 83/JAB/2025[2018-19]Status: DisposedITAT Jabalpur24 Sept 2025AY 2018-19

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2018-19 Sangeeta Gupta, Vs. Income Tax Officer, Ludhati, Itama, Maihar, Satna Ward-1, Satna Pan:Bdipg5378M (Appellant) (Respondent) Assessee By: Sh. Dhiraj Ghai, Ca Revenue By: Sh. N.M. Prasad, Sr. Dr Date Of Hearing: 21.08.2025 Date Of Pronouncement: 24.09.2025 O R D E R Per Nikhil Choudhary, A.M. This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit(A), Nfac Under Section 250 Of The Income Tax Act, 1961 On 18.02.2025 Dismissing The Appeal Of The Assessee In Limine. The Grounds Of Appeal Are As Under:- “1. On The Facts & Circumstance Of The Case, The Ld. Cit(A) Erred In Not Considering The Case As Bad In Law, As Has Been Initiated By Jao Instead Of Faceless. 2. On The Facts & Circumstances Of The Case, Case, The Id. Cit (A) Erred In Not Considering The Case As Bad In Law On Account Of Not Giving Sufficient Time Of 30 Days To Assessee To Reply The Notice Under Section 148A(B). 3. On The Fact & Circumstance Of The Case, The Id. Cit (A) Has Erred In Law As Well As On The Fact Of The Case In Dismissing The Appeal In Liming Without Condoning The Delay Even When There Exist Reason & Sufficient Cause Behind The Delay So Caused Was Beyond The Control Of The Appellant. 4. The Id. Cit (A) Erred In Law As Well As On The Fact Of The Case In Confirming The Addition Of 21,23,97,680/- Credited In The Bank Account Of The Assessee In Cash Form Without Considering The Fact That Assessee Duly Uploaded The Audit Report On E-Portal, Confirming The Source Of Cash. Further Id. Cit (A) Also Erred In Not Considering The Reply Filed In The Appeal Proceeding, As Well As In The Assessment Proceeding By Assessee, To Dismiss The Appeal Being Filed Beyond Allowable Time Having Sufficient Cause.

For Appellant: Sh. Dhiraj Ghai, CAFor Respondent: Sh. N.M. Prasad, Sr. DR
Section 115Section 142(1)Section 144Section 148Section 148ASection 234BSection 250Section 271ASection 69A

sale of mobile phone only. 7. Ld. CIT (A) erred in law as well as on the fact of the case in charging interest under section 234B and 234D of the Act. The assessee totally denies its liability to pay such interest. The interest so charged being contrary

Amruthavarshini Dairy Farms Private Limited, Vijayawada vs. Assistant Commissioner of Income-Tax, Central Circle-2(4) Hyderabad, Hyderabad

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

ITA 374/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam24 Sept 2025AY 2017-18

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member), SHRI S BALAKRISHNAN HON’BLE (Accountant Member)

Section 143(2)Section 143(3)Section 145(3)Section 69A

basis of cash deposit in bank account, under the facts and circumstances of the case. 8. The appellant denies the liability to pay interest under section 234B of the Act, in view of the fact that there is no liability to additional tax and determined

Sagarmal Khemraj Dagalia, Mumbai vs. Income Tax Officer 23(3)(5), Mumbai

The appeal of the assessee is allowed for statistical purposes

ITA 4125/MUM/2025[2017-18]Status: DisposedITAT Mumbai22 Sept 2025AY 2017-18

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Appellant: Shri Bhavin Solanki, ARFor Respondent: Shri Swapnil Choudhary, CIT-DR
Section 115BSection 133(6)Section 143(3)Section 234BSection 250Section 271ASection 69A

leading to higher cash holdings from silver utensil sales. 5. On Interest and Penalty 5.1 The CIT(A) erred in confirming:  Interest under Section 234B of Rs. 25,03,842/-, which is unsustainable if the addition is deleted.  Penalty proceedings under Section 271AAC, which are premature and without basis

ACIT, Cir 8(2)(1), Mumbai vs. Western India Garments Pvt. Ltd., Mumbai

In the result, appeal of the Revenue is dismissed and appeal of the assessee is allowed

ITA 4211/MUM/2023[2014-15]Status: DisposedITAT Mumbai22 Sept 2025AY 2014-15

Bench: Smt. Beena Pillai & Shri Girish Agrawalassessment Year: 2014-15 Pico Capital Private Limited Deputy Commissioner Of (Successor In Interest Of M/S Income Tax-8(3)(2), Western India Garments Private Mumbai Limited ) 22(1) Bombay Cotton Miis Vs. Compound, Dattaram Lad Path Kalachowky, Mumbai - 400033 (Pan: Aaacw2493G) (Appellant) (Respondent) Assessment Year: 2014-15 Deputy Commissioner Of Income Western India Garments Tax - 8(2)(1), Private Limited Mumbai 22(1) Bombay Cotton Miis Compound, Vs. Dattaram Lad Path Kalachowky, Mumbai - 400033 (Pan: Aaacw2493G) (Appellant) (Respondent) Present For: Assessee : Shri Dharan Gandhi, Advocate Revenue : Shri Arun Kanti Datta, Cit Dr Date Of Hearing : 03.07.2025 Date Of Pronouncement : 22.09.2025 O R D E R Pico Capital Pvt Ltd. & Western India Garments Pvt Ltd. Ay 2014-15 Per Girish Agrawal: These Two Appeals Filed By Assessee & Revenue Are Against The Order Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Vide Order No. Itba/Nfac/S/250/2023-24/1056675304(1), Dated 29.09.2023 Passed Against The Assessment Order By Dcit, Circle - 8(3)(2), Mumbai, U/S. 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 13.12.2016 For Assessment Year 2014- 15. 2. Grounds Taken By The Assessee Are Reproduced As Under: 1. The Ld. Cit(A), Nfac Has Erred In Confirming The Disallowance Of Rs. 13,52,543/- Made U/S 14A R.W.R. 8D Of The Rules Over & Above The Disallowance Of Rs. 11,02,185/- Made By The Appellant. 2. The Assessment Order U/S 143(3) Of The Act, Dated 13.12.2016 Is Bad In Law As The Same Has Been Passed In The Name Of The Non-Existent Person. 3. The Ld. Ao, Has Erred In The Levying Interest Under Section 234B Of The Act. 4. The Ld. Ao Erred In Initiating Penalty Proceedings U/S 271(1)(C) Of The Act.

For Appellant: Shri Dharan Gandhi, AdvocateFor Respondent: Shri Arun Kanti Datta, CIT DR
Section 143(3)Section 14ASection 234BSection 271(1)(c)Section 36(1)(vii)

same has been passed in the name of the non-existent person. 3. The Ld. AO, has erred in the levying interest under section 234B of the Act. 4. The Ld. AO erred in initiating penalty proceedings u/s 271(1)(c) of the Act. 2.1 Grounds taken by revenue

Pico Capital Private Limited (Successor in Interest of M/S Western India Garments Private Limited ), Mumbai vs. Deputy Commissioner of Income Tax-8(3)(2), Mumbai

In the result, appeal of the Revenue is dismissed and appeal of the assessee is allowed

ITA 4007/MUM/2023[2014-15]Status: DisposedITAT Mumbai22 Sept 2025AY 2014-15

Bench: Smt. Beena Pillai & Shri Girish Agrawalassessment Year: 2014-15 Pico Capital Private Limited Deputy Commissioner Of (Successor In Interest Of M/S Income Tax-8(3)(2), Western India Garments Private Mumbai Limited ) 22(1) Bombay Cotton Miis Vs. Compound, Dattaram Lad Path Kalachowky, Mumbai - 400033 (Pan: Aaacw2493G) (Appellant) (Respondent) Assessment Year: 2014-15 Deputy Commissioner Of Income Western India Garments Tax - 8(2)(1), Private Limited Mumbai 22(1) Bombay Cotton Miis Compound, Vs. Dattaram Lad Path Kalachowky, Mumbai - 400033 (Pan: Aaacw2493G) (Appellant) (Respondent) Present For: Assessee : Shri Dharan Gandhi, Advocate Revenue : Shri Arun Kanti Datta, Cit Dr Date Of Hearing : 03.07.2025 Date Of Pronouncement : 22.09.2025 O R D E R Pico Capital Pvt Ltd. & Western India Garments Pvt Ltd. Ay 2014-15 Per Girish Agrawal: These Two Appeals Filed By Assessee & Revenue Are Against The Order Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Vide Order No. Itba/Nfac/S/250/2023-24/1056675304(1), Dated 29.09.2023 Passed Against The Assessment Order By Dcit, Circle - 8(3)(2), Mumbai, U/S. 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 13.12.2016 For Assessment Year 2014- 15. 2. Grounds Taken By The Assessee Are Reproduced As Under: 1. The Ld. Cit(A), Nfac Has Erred In Confirming The Disallowance Of Rs. 13,52,543/- Made U/S 14A R.W.R. 8D Of The Rules Over & Above The Disallowance Of Rs. 11,02,185/- Made By The Appellant. 2. The Assessment Order U/S 143(3) Of The Act, Dated 13.12.2016 Is Bad In Law As The Same Has Been Passed In The Name Of The Non-Existent Person. 3. The Ld. Ao, Has Erred In The Levying Interest Under Section 234B Of The Act. 4. The Ld. Ao Erred In Initiating Penalty Proceedings U/S 271(1)(C) Of The Act.

For Appellant: Shri Dharan Gandhi, AdvocateFor Respondent: Shri Arun Kanti Datta, CIT DR
Section 143(3)Section 14ASection 234BSection 271(1)(c)Section 36(1)(vii)

same has been passed in the name of the non-existent person. 3. The Ld. AO, has erred in the levying interest under section 234B of the Act. 4. The Ld. AO erred in initiating penalty proceedings u/s 271(1)(c) of the Act. 2.1 Grounds taken by revenue

Wipro Ge Healthcare Pvt. Ltd., Bangalore vs. DCIT, New Delhi

In the result, the Appeal o f the Assessee is partly allowed

ITA 4521/DEL/2014[2007-08]Status: DisposedITAT Delhi12 Sept 2025AY 2007-08

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Wipro Ge Healthcare Pvt. Ltd. Vs. Dcit (Earlier Know As Ge Healthd Care Circle12(1) Pvt. Ltd.) 4, Kadugodi, Industrial New Delhi Area, Bangalore,Pan: Aaacw1685J Appellant Respondent Assessee By Sh. Sachit Jolly, Sr. Adv, Sh. Viyustirawat, Adv& Sh. Devansh Jain, Adv Revenue By Sh. S. K. Jadhav, Cit(Dr) Date Of Hearing 05/08/2025 Date Of Pronouncement 12/09/2025

Section 143(3)Section 144C(13)Section 144C(5)Section 153

without recording any adequate satisfaction for such initiation 12. That the Ld. AO erred in facts and in law in charging and computing interest under section 234B and 234D of the Act The above grounds of appeal are mutually exclusive and without prejudice to each other. The Appellant craves leave

Pfizer Limited (Formerly Known As Wyeth Limited), Mumbai vs. The ACIT Cir 7(3), Mumbai

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

ITA 97/MUM/2005[1994-1995]Status: DisposedITAT Mumbai11 Sept 2025AY 1994-1995

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Sandeep Singh Karhail, Hon’Ble

For Appellant: Shri Vishal Kalra (virtually appeared) and Ms. Manish Pal, A/RsFor Respondent: Shri Leyaqat Ali Aafaqui, Sr. A/R
Section 143(3)Section 147

decision of the ITAT in second appeal filed against order under section 143(3). (6) The CIT(A) erred in holding that interest under section 234B is mandatory and accordingly the AO was justified in levying the interest. Your appellants submit that provisions of section 234B are not attracted

The Dy.CIT-14(1)(1), Mumbai vs. M/S Pfizer Ltd (Formerly Known S Wyeth Lederle Ltd, Mumbai

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

ITA 327/MUM/2005[1994-1995]Status: DisposedITAT Mumbai11 Sept 2025AY 1994-1995

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Sandeep Singh Karhail, Hon’Ble

For Appellant: Shri Vishal Kalra (virtually appeared) and Ms. Manish Pal, A/RsFor Respondent: Shri Leyaqat Ali Aafaqui, Sr. A/R
Section 143(3)Section 147

decision of the ITAT in second appeal filed against order under section 143(3). (6) The CIT(A) erred in holding that interest under section 234B is mandatory and accordingly the AO was justified in levying the interest. Your appellants submit that provisions of section 234B are not attracted

Orbis Real Estate Fund I, Hyderabad (Auth. Rep.) vs. ADIT (International Taxation)-2 - 2, Hyderabad

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

ITA 785/HYD/2024[2020-2021]Status: DisposedITAT Hyderabad10 Sept 2025AY 2020-2021

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

For Appellant: Shri Sai Sourabh K, C.AFor Respondent: Dr. Narender Kumar Naik
Section 143(3)Section 154

sale of immoveable property u/s 48 of the Income tax Act, 1961. (10) Without prejudice to the above grounds, Ld. AO has charged interest under section 234B and 234C despite the TDS Amount being sufficient to cover the entire tax liability computed as per contested grounds. (11) Without prejudice

Godrej Projects North Star LLP, Mumbai vs. Deputy Commissioner of Income Tax Circle41(2)(1), Mumbai

Appeal of the assessee is allowed

ITA 4258/MUM/2025[2024-25]Status: DisposedITAT Mumbai10 Sept 2025AY 2024-25

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

Section 140Section 140ASection 143Section 143(1)Section 234ASection 234BSection 234B(2)Section 250Section 39Section 94

grounds of appeal: 1. The Appellant LLP objects to the tax determined payable. 2. The Appellant LLP objects to the erroneous levy of interest under Section 234B of the Act for the year under consideration. It is respectfully submitted that the Assessing Officer Centralized Processing Centre, Bengaluru has exceeded his/its ... jurisdiction and the erroneous levy of interest under Section 234B of the Act is unwarranted. 3. The Intimation issued under Section 143(1) of the Act is illegal and without jurisdiction as it raises a debatable issue. 4. The Appellant LLP denies the liability towards the erroneous excess levy

Akhilesh Singh Bhadauria, Delhi vs. ITO, Ward-58(2), Delhi

The appeal is allowed

ITA 2349/DEL/2024[2010-11]Status: DisposedITAT Delhi10 Sept 2025AY 2010-11

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year: 2010-11 Akhilesh Singh Bhadauria, Vs Ito, A-19, Ground Floor, Ward-58(2), Ghazipur Village, Delhi. Delhi – 110 096 Pan: Altpb9329H (Appellant) (Respondent) Assessee By : Shri Amit Kumar Gupta, Advocate Revenue By : Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing : 14.08.2025 Date Of Pronouncement : 10.09.2025

For Appellant: Shri Amit Kumar Gupta, AdvocateFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 144Section 147Section 234BSection 271(1)(c)Section 282Section 69A

considering the affidavit filed by the assessee. 10) The Ld. AO has erred both on facts and in law in levying interest under section 234B and 234C of the Act. 11) The Ld.AO has erred both on facts and in law in initiating penalty proceedings under section

Kothari Agritech Pvt. Ltd, Solapur vs. The DCIT, Circle-1, Solapur

In the result, the both appeals of the assessee in ITA Nos

ITA 2455/PUN/2024[2018-2019]Status: DisposedITAT Pune09 Sept 2025AY 2018-2019

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

For Appellant: Shri Nikhil TiwariFor Respondent: Shri Ramnath P Murkunde
Section 143Section 143(1)Section 143(1)(a)Section 143(3)Section 14ASection 154Section 80Section 801ASection 80ISection 80J

revised return of income which was allowed in the course of the assessment proceedings by the learned AO; Erroneous levy of interest under section 234B and section 234C of the Act 5. The learned AO has erred on the facts and in circumstance of the case ... proposing to levy additional interest under section 234B and section 234C of the Act as compared to the return of income. Initiation of penalty proceedings under section 274 read with section 270A of the Act 6. The learned AO has erred in initiating penalty proceedings against the Appellant under section