“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

Hdfc Bank Limited (As Successor to Hdfc Limited Which in Turn Was A Successor to Hdfc Investments Li, Mumbai vs. The Deputy Commissioner of Income-Tax, Circle 2(3)(1), Mumbai

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

ITA 4208/MUM/2025[2020-21]Status: DisposedITAT Mumbai20 Aug 2025AY 2020-21

Bench: Shri Amit Shukla & Shri Arun Khodpiaआयकर अपील सं. / Ita No.4208/Mum/2025 "नधा"रण वष" / Assessment Year :2020-21 Hdfc Bank Limited (Successor To Hdfc Limited Which In Turn Was A Successor To Hdfc Investments Limited) Hdfc Bank House, Senapati Bapat Marg, Lower Parel (W), Mumbai-400 013 Pan : Aaach2702H/Aaach1462L

For Appellant: Shri Ketan VedFor Respondent: Shri Hemanshu Joshi, Sr. DR

Section 234BSection 80G

erred in not appreciating that deduction under section 80G is available on contribution made towards Corporate Social Responsibility. 3. Re.: Interest under Section 234B of the Act 3 HDFC Bank Limited Vs. DCIT, Circle-2(2)(1), Mumbai 3.1 On the facts and in circumstances of the case ... facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred in not considering that the interest under section 234B of the Act has been incorrectly computed at Rs. 43,404 instead of Rs. 41,984 as per the return of income filed

Bhupesh Sharma, New Delhi vs. ITO, New Delhi

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

ITA 3083/DEL/2025[2018-19]Status: DisposedITAT Delhi20 Aug 2025AY 2018-19

Bench: Shri M. Balaganeshbhupesh Sharma, Vs. Ito, House No. 1-202, Ward-36(1), Prashant Vihar, Rohini, Delhi Sector-16, New Delhi Pan: Asops8305C

For Appellant: Shri Raghav Sharma, CAFor Respondent: Shri Manoj Kumar, Sr. DR

Section 115Section 147Section 148Section 234ASection 234BSection 234CSection 69A

return in response to notice under section 148 of the Act and the actual date of filing the return. The levy of interest under section 234B of the Act is consequential in nature. With regard to interest under section 234C of the Act, the law is well settled that

Indian Metals and Ferro Alloys Ltd, Bhubaneswar vs. DCIT, Circle-1(1), Bhubaneswar

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

ITA 506/CTK/2024[2021-22]Status: DisposedITAT Cuttack19 Aug 2025AY 2021-22

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

Section 143(1)Section 143(2)Section 143(3)Section 144C(5)Section 234BSection 234CSection 270ASection 92CSection 92D

Ferro Alloys Ltd. 6. That on the facts and circumstances of the case and in law, the Ld. AO has erred in imposing interest under Section 234B and Section 234C of the Act. 7. That on the facts and circumstances of the case

Smt Sushama Rajesh Rao, Bangalore vs. Deputy Commissioner of Income Tax Circle-5(2)(1), Bangalore

In the result, appeal of the assessee is allowed

ITA 49/BANG/2023[2012-13]Status: DisposedITAT Bangalore18 Aug 2025AY 2012-13

Bench: Shri Prashant Maharishi & Shri Soundararajan Kassessment Year: 2012-13 Sushama Rajesh Rao, Vs. The Deputy Commissioner No.159, Priyadarshani, R. T. Nagar, Of Income Tax, Mla Layout, Circle – 6(2)(1), Bangalore – 560 032. Bangalore. Pan : Acypr 5251 J Appellant Respondent Appellant By : Shri. V. Chandrashekar, Advocate Respondent By : Shri. Muthu Shankar, Cit(Dr)(Itat), Bangalore. Date Of Hearing : 23.07.2025 Date Of Pronouncement : 18.08.2025

For Appellant: Shri. V. Chandrashekar, AdvocateFor Respondent: Shri. Muthu Shankar, CIT(DR)(ITAT), Bangalore

Section 234BSection 250Section 49Section 50(2)Section 50C

consequently such assessment is without jurisdiction on the facts and circumstances of the case. 13. 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 as determined by the assessing officer. Without prejudice

Rubicon Research Limited (Formerly Known As Rubicon Research Private Limited), Thane, Maharashtra vs. Deputy Commissioner of Income Tax - Circle 15(3)(1), Mumbai

In the result, assessee’s appeal is allowed for statistical purposes

ITA 6647/MUM/2024[2021-22]Status: DisposedITAT Mumbai18 Aug 2025AY 2021-22

Bench: Smt. Beena Pillai & Smt. Renu Jauhriआयकर अपील सं./Ita No.6647/Mum/2024 (निर्धारण वर्ा/Assessment Year: 2021-22) Rubicon Research V/S. Deputy Commissioner Of Limited (Formerly बिधम Income Tax- Circle Known As Rubicon 15(3)(1), Mumbai Research Private Aaykar Bhavan, Maharshi Limited) Karve Road, New Marine Medone House, B-75, Lines, Churchgate, Mumbai Road No. 33, Wagle 400020 Estate, Thane 400604. Assessment Unit, National Faceless Assessment Centre Income Tax Department, Ministry Of Finance Delhi स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabcr1422M Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी निर्ााररती की ओर से /Assessee By: Shri. Darpan Kirpalani रधजस्व की ओर से /Revenue By: Shri. Asif Karmali (Sr Dr)

For Appellant: Shri. Darpan KirpalaniFor Respondent: Shri. Asif Karmali (SR DR)

Section 143(3)Section 153Section 234BSection 37Section 92CSection 92C(3)Section 92D

have further erred in disallowing the said payment u/s 37 of the Act. 7. Levying the consequential interest under Section 234B /234C/234D of the Act. The Appellant prays that the additions made by the Ld. TPO /Ld. AO under the directions of the Hon'ble DRP be deleted and consequential

Procter and Gamble Health Private Limited, Mumbai vs. The Pr. Commissioner of Income Tax -8, Mumbai

In the result, appeal of the assessee is allowed

ITA 2326/MUM/2025[2018-19]Status: DisposedITAT Mumbai14 Aug 2025AY 2018-19

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

For Appellant: Ms. Aarti Vissanji & Shri Ajay BhandariFor Respondent: Shri R A Dhyani, CIT D/R

Section 143(3)Section 144BSection 263Section 40Section 50CSection 56(2)(x)Section 68

Provision (Higher of A&B) Tax provision required in books Less: Tax Deducted At Source Certificates Received - As per 26AS Assessed Tax Add: Interest under section 234B of the Act Assessed Tax 90% of assessed tax Advance tax paid Shortfall in payment of advance tax as compared

Chanderakanta H Lalia, Navi Mumbai vs. ITO, 28(1)(3), Vashi Railway Station

The appeal is dismissed as having become

ITA 5693/MUM/2024[2014-2015]Status: DisposedITAT Mumbai14 Aug 2025AY 2014-2015

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2014-15 Chanderakanta H Lalia, Ito, 28(1)(3), C/O Shri Shamji Bhanushali, Room No. 327, Tower No. 6, Chartered Accountant, 339, Big Vs. Vashi Railway Station Splash, Section -17, Vashi, Commercial Complex, Vashi, Navi Mumbai- 400703. Navi Mumbai-400703. Pan No. Ajvpl 7788 C Appellant Respondent

For Respondent: Mr. Vimal Punmiya

Section 143(3)Section 148Section 234BSection 69A

erred in confirming charging of interest under section (Appeals) erred in confirming charging of interest under section (Appeals) erred in confirming charging of interest under section 234B and 234C and 234B and 234C and 234D of the Act Before us, learned counsel for the assessee submits that, for 2. Before

Sunflower Aircraft Leasing Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 4(2)(2) International Tax, Mumbai

In the result, the appeal of the assessee stands allowed

ITA 1107/MUM/2025[2022-23]Status: DisposedITAT Mumbai13 Aug 2025AY 2022-23

Section 143(3)Section 144C(13)Section 144C(5)Section 9(1)(vi)

chargeable as interest is beyond jurisdiction and hence, set aside. 46. In Ground of Appeal No.5.6, the assessee has challenged the levy of interest under section 234B. Interest under section 234B is consequential. Since we have deleted the addition, deletion of interest will be consequential. 47. In Ground of Appeal

Pushpavati Janardhan Rao, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle 4 (3), Mumbai

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

ITA 4243/MUM/2025[2018-19]Status: DisposedITAT Mumbai12 Aug 2025AY 2018-19

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

For Appellant: Ms. Vinita Nara, A/RFor Respondent: Mr. Virabhadra S. Mahajan, Sr. D/R

Section 143(3)Section 144B(1)Section 144B(9)Section 234BSection 271A

despite the fact that the same was not the reason for limited scrutiny. 6. The Learned Assessing Officer erred in levying interest under section 234B, 234C and initiating penalty proceeding u/s 271A and 271A of the Act without appreciating the fact that the appellant denies his liability to the same

Kiran Baburao Jadhav, Pune vs. DCIT, Pmt Building Swargat

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

ITA 805/PUN/2025[2023-2024]Status: DisposedITAT Pune11 Aug 2025AY 2023-2024

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2023-24 Shri Kiran Baburao Jadhav Dcit, Swargate, Pune Flat No.4, Shubhamkar Apts, Lane Vs. No.14, Bhandarkar Road, Pune – 411004 Pan: Addpj5634M (Appellant) (Respondent) Assessee By : Shri Gajanan N Kondhare Department By : Shri Ramnath P Murkunde Date Of Hearing : 28-07-2025 Date Of Pronouncement : 11-08-2025 O R D E R

For Appellant: Shri Gajanan N KondhareFor Respondent: Shri Ramnath P Murkunde

Section 115JSection 139Section 140BSection 143Section 143(1)Section 208Section 210Section 234BSection 234B(1)Section 89

interest paid in an earlier return. Further, an additional income tax shall be paid before filing an updated return. (a)…. (b)…. (c) Interest under section 234B - Where a person has already filed the original, belated, or revised return for the relevant assessment year and subsequently files an updated return, Section ... 140B provides that interest under section 234B at the time of furnishing of updated return shall be computed on the amount of assessed tax or on the amount by which the advance tax paid falls short of the assessed tax, as the case may be. An assessee may be liable

Yogita Bipin Kharade, Mumbai vs. Income Tax Officer Ward 42(1)(4), Mumbai

Appeal of the assessee is allowed for statistical purposes

ITA 4096/MUM/2025[2013-14]Status: DisposedITAT Mumbai11 Aug 2025AY 2013-14

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri Himanshu Gandhi & Shri

Section 234BSection 250Section 271(1)(c)Section 54F

facts and circumstances of the case and law, the Ld. CIT(A) erred in confirming charging of interest under section 234B of Income Tax Act, 1961. 6. On the facts and circumstances of the case and law, the Ld. CIT(A) erred in confirming initiation of Penalty proceedings under section

Shri Kishore Mohanlal Dingra, Mumbai vs. DCIT, Cir-41(1)(1), Mumbai

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

ITA 2257/MUM/2024[2016-17]Status: DisposedITAT Mumbai11 Aug 2025AY 2016-17

Bench: Shri Anikesh Banerjee & Smt. Renu Jauhriआयकर अपील सुं./Ita No.2257/Mum/2024 (नििाारण वर्ा / Assessment Year: 2016-17) Shri Kishore V/S. Deputy Director Of Income Mohanlal Dingra बिाम Tax Circle 41(1)(1), Mumbai 105, Dosti Ambrosia, The Of Dcit, Circle 4(1)(1), S.M. Road, Mumbai Kautilya Bhavan, Room No. 400037 Kb/614, Bandra Kurla Complex, Bandra East, Mumbai 400051 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Atxpd4896P Appellant/अपीलार्थी .. Respondent/प्रनिवादी निर्ााररती की ओर से /Assessee By: Shri Nimish Thar राजस्व की ओर से /Revenue By: Shri. Hemanshu Joshi, Sr Dr

For Appellant: Shri Nimish TharFor Respondent: Shri. Hemanshu Joshi, SR DR

Section 143(3)Section 234ASection 234BSection 250Section 44A

Learned CIT (A) has erred in law & on facts in upholding the Learned AO's action of imposing interest under Section 234B of the Income Tax Act, 1961. 7) The Appellant craves leave to add to and/ or amend and/ or delete and/or modify and/or alter the aforesaid grounds

Xilinx India Technology Services Private Limited, Hyderabad vs. Dy. Commissioner of Income Tax, Circle-17(2), Hyderabad

In the result, the appeals filed by the assessee is partly allowed

ITA 1761/HYD/2019[2015-16]Status: DisposedITAT Hyderabad08 Aug 2025AY 2015-16

For Appellant: Shri SP Chidambaram, AdvocateFor Respondent: Shri B. Bala Krishna, CIT-DR

Section 143(3)Section 144C(5)Section 92C

TPO/AO/DRP erred in not granting working capital adjustment to the Appellant. 20. That the consequential effect should be given to the liability of interest under section 234B and 234D. 21. The Appellant craves, to consider each of the above grounds of appeal without prejudice to each other and craves leave

Raghav Kumar Dhoot, Jaipur vs. DCIT Central Circle 1, Jaipur

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

ITA 491/JPR/2025[2018-19]Status: DisposedITAT Jaipur06 Aug 2025AY 2018-19

For Appellant: Shri C.M. Agarwal, C.AFor Respondent: Shri Rajesh Ojha, CIT- DR

Section 143(2)Section 143(3)Section 153ASection 292BSection 68

judgment, relying on the aforementioned judgment of this Court passed in the case of Ajay Prakash Verma (supra), has erroneously held that the interest under section 234B could be charged on the returned income and not on the assessed income. The Ld. ITAT has not even considered the provisions ... Haryana) [20-07-2010] that even if assessee, on a bona fide calculation, found that no advance tax was payable, still liability of interest under section 234B would be attracted on income assessed under section 143(1) or 143(3). The relevant para are as under:- 7. The matter

Deputy Commissioner of Income Tax, Circle-3(1)(1), Bengaluru vs. Infosys Limited, Bengaluru

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

ITA 245/BANG/2024[2019-20]Status: DisposedITAT Bangalore06 Aug 2025AY 2019-20

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2019-20

For Appellant: Sri Padam Chand Khincha – CAFor Respondent: Smt. Srinandini Das – CIT - DR

Section 1Section 10ASection 155Section 250

relation to income on which deduction under section 10AA was claimed) once the dispute is settled 5. Levy of interest under section 234B: 5.1. The levy of interest under section 234B is bad in law and liable to be quashed. 6. Prayer: 6.1. Based on the above grounds and other ... Accordingly, the Ground No 4 of the assessee is also allowed. 12. The Ground No 5 dealing with levy of interest under section 234B is consequential in nature. 13. The assessee has filed the additional grounds of appeal at the time of hearing of the appeal with regard

Infosys Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

Accordingly, the appeal filed by the assessee is also allowed for statistical purposes

ITA 1532/BANG/2024[2021-22]Status: DisposedITAT Bangalore06 Aug 2025AY 2021-22

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Sri Padam Chand Khincha – CAFor Respondent: Smt Srinandini Das – CIT - DR

Section 10ASection 143(3)Section 234BSection 250

been allowed in appellant's own case for the earlier years by the High Court of Karnataka and ITAT, Bangalore. 4. Levy of interest under section 234B: 4.1. The levy of interest under section 234B is bad in law and liable to be quashed. 5. Prayer: 5.1. Based ... allowed for statistical purposes. ITA Nos.1531 & 1532/Bang/2024 Infosys Limited Page 14 of 16 8. The ground No 4 contesting the levy of interest under section 234B of the Act which is consequential in nature. The amount of interest if any will have to be worked out, post the giving effect

Infosys Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

Accordingly, the appeal filed by the assessee is also allowed for statistical purposes

ITA 1531/BANG/2024[2020-21]Status: DisposedITAT Bangalore06 Aug 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Sri Padam Chand Khincha – CAFor Respondent: Smt Srinandini Das – CIT - DR

Section 10ASection 143(3)Section 234BSection 250

Infosys Limited, Bangalore vs. Deputy Commissioner of Income-Tax, Circle-3(1)(1), Bangalore

ITA 881/BANG/2023[2019-20]Status: DisposedITAT Bangalore06 Aug 2025AY 2019-20

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

Section 1Section 10ASection 155Section 250

M/S. Philips International B.V., Kolkata vs. ACIT (International Taxation), Circle 2(1), Kolkata

In the result, appeal of the assessee in ITA No

ITA 544/KOL/2025[2022-23]Status: FixedITAT Kolkata05 Aug 2025AY 2022-23

Bench: Shri George Mathan & Shri Rakesh Mishra

For Appellant: Ms. Riya Shah, CAFor Respondent: Shri Praveen Kishore, CIT-DR

Section 143(3)

instead of levying a flat tax rate of 10% as per Article 12 to the India- Netherlands DTAA. 4. Erroneous levy of Interest under section 234B 4.1 That on the facts and in the circumstances of the case and in law, the Ld. AO erred in levying interest under section

M/S. Philips Electronics Nederland B.V., Kolkata vs. ACIT (International Taxation), Circle 2(1), Kolkata

In the result, appeal of the assessee in ITA No

ITA 543/KOL/2025[2022-23]Status: FixedITAT Kolkata05 Aug 2025AY 2022-23

Bench: Shri George Mathan & Shri Rakesh Mishra

For Appellant: Ms. Riya Shah, CAFor Respondent: Shri Praveen Kishore, CIT-DR

Section 143(3)