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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

Lovely Das, Dum Dum vs. Addl/JCIT, Nashik

In the result, all the four appeals are allowed for statistical purpose

ITA 294/KOL/2025[2022-2023]Status: DisposedITAT Kolkata04 Aug 2025AY 2022-2023

Bench: Sonjoy Sarma & Sri Rakesh Mishra

Section 143Section 143(1)Section 234ASection 234BSection 250

name of Late Jagbandhu Das. 4. That the Learned Assessing Officer and ADDL/JCIT(A)-1-NASHIK also has erred in computing Interest under Section 234B of Rs.3,07,692 and 234C of Rs. 1,16,824 as against the assessee’s computation of Rs. NIL and Rs.28,701 respectively under ... naturally in the name of Late Jagbandhu Das. 5. That the Learned Assessing Officer and ADDL/JCIT(A)-NASHIK has erred in computing Interest under Section 234B of Rs. 1,83,651 and 234C of Rs. 1,14,497 as against the assessee’s computation of Rs. NIL and Rs.40

Lovely Das, Dum Dum vs. Addl/JCIT, Nashik

In the result, all the four appeals are allowed for statistical purpose

ITA 293/KOL/2025[2021-2022]Status: DisposedITAT Kolkata04 Aug 2025AY 2021-2022

Bench: Sonjoy Sarma & Sri Rakesh Mishra

Section 143Section 143(1)Section 234ASection 234BSection 250

name of Late Jagbandhu Das. 4. That the Learned Assessing Officer and ADDL/JCIT(A)-1-NASHIK also has erred in computing Interest under Section 234B of Rs.3,07,692 and 234C of Rs. 1,16,824 as against the assessee’s computation of Rs. NIL and Rs.28,701 respectively under ... naturally in the name of Late Jagbandhu Das. 5. That the Learned Assessing Officer and ADDL/JCIT(A)-NASHIK has erred in computing Interest under Section 234B of Rs. 1,83,651 and 234C of Rs. 1,14,497 as against the assessee’s computation of Rs. NIL and Rs.40

Lovely Das, Dum Dum vs. Addl/JCIT, Nashik

In the result, all the four appeals are allowed for statistical purpose

ITA 292/KOL/2025[2020-2021]Status: DisposedITAT Kolkata04 Aug 2025AY 2020-2021

Bench: Sonjoy Sarma & Sri Rakesh Mishra

Section 143Section 143(1)Section 234ASection 234BSection 250

name of Late Jagbandhu Das. 4. That the Learned Assessing Officer and ADDL/JCIT(A)-1-NASHIK also has erred in computing Interest under Section 234B of Rs.3,07,692 and 234C of Rs. 1,16,824 as against the assessee’s computation of Rs. NIL and Rs.28,701 respectively under ... naturally in the name of Late Jagbandhu Das. 5. That the Learned Assessing Officer and ADDL/JCIT(A)-NASHIK has erred in computing Interest under Section 234B of Rs. 1,83,651 and 234C of Rs. 1,14,497 as against the assessee’s computation of Rs. NIL and Rs.40

Lovely Das, Dumdum vs. Addl/JCIT, Nashik

In the result, all the four appeals are allowed for statistical purpose

ITA 291/KOL/2025[2019-2020]Status: DisposedITAT Kolkata04 Aug 2025AY 2019-2020

Bench: Sonjoy Sarma & Sri Rakesh Mishra

Section 143Section 143(1)Section 234ASection 234BSection 250

name of Late Jagbandhu Das. 4. That the Learned Assessing Officer and ADDL/JCIT(A)-1-NASHIK also has erred in computing Interest under Section 234B of Rs.3,07,692 and 234C of Rs. 1,16,824 as against the assessee’s computation of Rs. NIL and Rs.28,701 respectively under ... naturally in the name of Late Jagbandhu Das. 5. That the Learned Assessing Officer and ADDL/JCIT(A)-NASHIK has erred in computing Interest under Section 234B of Rs. 1,83,651 and 234C of Rs. 1,14,497 as against the assessee’s computation of Rs. NIL and Rs.40

Karnataka Power Corporation Limited, Bengaluru vs. ACIT, Circle-4(1)(1), Bengaluru

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

ITA 370/BANG/2025[2019-20]Status: DisposedITAT Bangalore04 Aug 2025AY 2019-20

Bench: Shri Narender Kumar Choudhry & Shri Waseem Ahmed

For Appellant: Sri V. Narendra Sharma, Ld. AdvocateFor Respondent: Sri Shivanand H. Kalakeri, Ld.CIT
Section 143Section 154Section 246ASection 250Section 253Section 36Section 43B

income to the tune of Rs. 8,03,98,978/- resulting in a short levy of tax, Rs. 2,80,94,618/- and interest under section 234B of Rs. 84,28,386/- aggregating to Rs. 3,65,23,004/-• 9. The Petitioner / Appellant being aggrieved by the said order

Karnataka Power Corporation Limited, Bengaluru vs. ACIT, Circle-4(1)(1), Bengaluru

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

ITA 369/BANG/2025[2019-20]Status: DisposedITAT Bangalore04 Aug 2025AY 2019-20

Bench: Shri Narender Kumar Choudhry & Shri Waseem Ahmed

For Appellant: Sri V. Narendra Sharma, Ld. AdvocateFor Respondent: Sri Shivanand H. Kalakeri, Ld.CIT
Section 143Section 154Section 246ASection 250Section 253Section 36Section 43B

income to the tune of Rs. 8,03,98,978/- resulting in a short levy of tax, Rs. 2,80,94,618/- and interest under section 234B of Rs. 84,28,386/- aggregating to Rs. 3,65,23,004/-• 9. The Petitioner / Appellant being aggrieved by the said order

Deputy Commissioner of Income Tax, Circle 1(1)(1), Bangalore vs. Silicon Estates, Bangalore

ITA 1534/BANG/2024[2014-15]Status: DisposedITAT Bangalore04 Aug 2025AY 2014-15

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2014-15 M/S. Silicon Estates Dcit No.14, 6Th Floor, Hm Geneva Central Circle-1(4) House C.R. Building, No.1, Queens Cunningham Road Vs. Road Bengaluru 560052 Bangalore-560001 Pan No :Abefs6150N Appellant Respondent Assessment Year : 2014-15 Dcit M/S. Silicon Estates Central Circle-1(1)(1) No.14, 6Th Floor, Hm Geneva House Room No. 215, 2Nd Floor Cunningham Road Vs. Bmtc Building, Kormangala Bengaluru 560052 Bangalore – 560095 Appellant Respondent

For Appellant: Sri Annamalai, A.RFor Respondent: Sri Subramanian S., D.R
Section 234BSection 250Section 80

treated as dismissed for statistical purpose on the facts and circumstances of the case. 7. The Appellant denies itself liable to be charged interest under Section 234B of the Act in respect of the extent of disallowance of deduction under section80-IB(10) of the Act confirmed by the learned

M/S. Silicon Estates, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-1(4), Benglauru

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

ITA 1526/BANG/2024[2014-15]Status: DisposedITAT Bangalore04 Aug 2025AY 2014-15

Bench: Shri Waseem Ahmed

Section 234BSection 250Section 80

treated as dismissed for statistical purpose on the facts and circumstances of the case. 7. The Appellant denies itself liable to be charged interest under Section 234B of the Act in respect of the extent of disallowance of deduction under section80-IB(10) of the Act confirmed by the learned

Arup Banerji, Allahabad vs. Deputy Commissioner of Income Tax Circle-1, Allahabad

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

ITA 154/ALLD/2024[2015-16]Status: DisposedITAT Allahabad31 Jul 2025AY 2015-16

Bench: SH. SUBHASH MALGURIA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. S.K. Jaiswal, C.AFor Respondent: Sh. A.K. Singh, Sr. DR
Section 133(6)Section 143(3)Section 234BSection 250Section 43Section 43(5)Section 5

transaction in respect of 'Derivative Trading ' is specifically excluded from the definition of 'speculative transaction'. 5. BECAUSE the appellant denies for levy of interest under section 234B and 234C of the Income Tax Act, 1961. 6. BECAUSE the order appealed against is contrary to the facts, law and principle

Skyhigh Infraprojects Private Ltd., Lucknow vs. Income Tax Officer-6(1), Lucknow

ITA 242/LKW/2025[2017-18]Status: DisposedITAT Lucknow31 Jul 2025AY 2017-18

Bench: Shri Sudhanshu Srivastava & Shri, Nikhil Choudhary

For Appellant: Shri P. K. Kapoor, CAFor Respondent: Shri Amit Kumar, DR
Section 133(6)Section 143Section 143(2)Section 143(3)Section 250Section 250(6)Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL LUCKNOW BENCH “A”, LUCKNOW BEFORE SHRI SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SHRI, NIKHIL CHOUDHARY

M/S. Bodal Chemicals Ltd., Ahmedabad vs. The Dy.CIT, Circle-1, Ahmedabad

In the result, the appeals being IT(SS)A No

ITA 318/AHD/2022[2009-10]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2009-10

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

For Appellant: Shri S.S. Nagar, ARFor Respondent: Shri Kamlesh Makwana, CIT-DR and Shri B.P. Srivastava, Sr.DR
Section 115JSection 132(1)Section 139(1)Section 139(5)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153A(1)(a)Section 153A(1)(b)

record. The Hon’ble Apex Court in case of Rolta Ltd. (supra) has categorically held that the assessee cannot envisage any liability of interest under Section 234B and 234C of the Income Tax Act, 1961 as on the date of filing the return of income. Thus, following the said decision ... Apex Court, the CIT(A) has rightly directed the Assessing Officer not to charge interest under Section 234B on returned income for any delay in depositing self assessment tax. As regards interest under Section 234C of the Act the same is always levied on return income, hence

Varun Batra, Mumbai vs. National Faceless Appeal Centre (NFAC), Delhi

In the result, the appeal filed by the assessee is hereby dismissed

ITA 3205/MUM/2022[2013-14]Status: DisposedITAT Mumbai31 Jul 2025AY 2013-14

Bench: Ms. Kavitha Rajagopal, Jm & Shri Prabhash Shankar, Am Varun Batra National Faceless Appeal Centre Flat 5, 5Th Floor, La Mer, Mistry Park, (Nfac) Kadeshwari Temple Road, Bandra Vs. West, Mumbai – 400050. Pan/Gir No. Aezpb9157L (Appellant) : (Respondent) Assessee By : None Respondent By : Ms. Kavita P. Kaushik, (Sr Dr) Date Of Hearing : 01.07.2025 Date Of Pronouncement : 31.07.2025 O R D E R Per Kavitha Rajagopal, J M: This Appeal Has Been Filed By The Assessee, Challenging The Order Of The Learned Commissioner Of Income Tax (Appeals) Delhi (‘Ld. Cit(A)’ For Short), National Faceless Appeal Centre (‘Nfac’ For Short) Passed U/S.250 Of The Income Tax Act, 1961 (‘The Act'), Pertaining To The Assessment Year (‘A.Y.’ For Short) 2013-14. 2. The Assessee Has Raised The Following Grounds Of Appeal: 1. That The Learned Commissioner Of Income Tax (Appeals), Delhi Has Grossly Erred Both In Law And, On Facts In Upholding The Determination Of Total Income Of The Appellant At Rs. 2,46,16,528/- As Against Declared Income At Rs. 2,30,52,930/- In An Order Of Assessment Dated 18.03.2016 U/S 143(3) Of The Act. 2. That The Learned Commissioner Of Income Tax (Appeals), Delhi Has Grossly Erred Both In Law & Fact In Holding That Sum Of Rs. 15,33,595/-Representing Loss On Account Of Share Trading. Varun Batra

For Appellant: NoneFor Respondent: Ms. Kavita P. Kaushik, (SR DR)
Section 143(2)Section 143(3)Section 234BSection 234CSection 250Section 68Section 71Section 72

Batra 4 That the learned Commissioner of Income Tax (Appeals) has erred both in law and on facts in upholding the levy of interest under section 234B, and interest u/s 234C of the Act which are not leviable on the facts and circumstances of the case of the appellant

Msg All Trading International Private Limited, East Azad Nagar vs. DCIT, Circle-11(1), Delhi

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

ITA 3195/DEL/2023[2016-17]Status: DisposedITAT Delhi31 Jul 2025AY 2016-17

Bench: Ms.Madhumita Roy & Shri Manish Agarwal[Assessment Year : 2016-17] Msg All Trading International Vs Dcit, Pvt.Ltd., Office No.2, 3Rd Floor, Circle-11(1), 80, East Azad Nagar, Delhi Raghuvarpura, Shahdara, Delhi-110051. Pan-Aajcm6792K Appellant Respondent Appellant By Shri Ved Jain, Adv., Shri Aman Garg, Ca & Ms. Ishika Dua, Ca Respondent By Shri Virender Kumar Singh, Sr.Dr Date Of Hearing 08.05.2025 Date Of Pronouncement 31.07.2025 Order

Section 143(3)Section 147Section 148Section 151Section 250Section 68

credit. 15. On the facts and circumstances of the case the learned AO has erred both on facts and in law in charging interest under Section 234B of the Act. 16. The appellant craves leave to add, amend or alter any of the grounds of appeal.” In Ground

Feroze Naval Patch, Mumbai vs. ITO Ward 19(1)(5), Mumbai

In the result, appeal of the assessee is allowed

ITA 1269/MUM/2025[2022-23]Status: DisposedITAT Mumbai30 Jul 2025AY 2022-23

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: NoneFor Respondent: Ms. Kavita P. Kaushik, Sr. D/R
Section 140ASection 140BSection 143Section 143(1)Section 234BSection 234B(2)

assessee reads as under:- “1) In the facts and circumstances of the case and in law, the learned A.O. erred in incorrectly determining interest under section 234B to be Rs. 8,27,421/- instead of Rs. 2,40,219/- determined by the assessee while filing updated return

Govind Prasad, Agra vs. ITO, Ward-2(1)(5), Agra

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

ITA 250/AGR/2025[2019-20]Status: DisposedITAT Agra29 Jul 2025AY 2019-20

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

Section 143(1)Section 234BSection 250(6)

extent making variation in the Income returned by the 'appellant' is bad both on facts and in law. 8. BECAUSE, charging of interest under section 234B is wrong and the same in any case are unreasonable and excessive.” Brief facts of the case:- In this case, vide order

Vijaya Singh, Patna vs. Income Tax Officer, Ward - 6(1), Patna, Bihar

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

ITA 519/PAT/2024[2018-19]Status: DisposedITAT Patna28 Jul 2025AY 2018-19

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 519/Pat/2024 Assessment Year: 2018-2019 Vijaya Singh,…………………………...….………Appellant M-55/22A, S.K. Nagar, Patna-800001, Bihar [Pan:Asups6086N] -Vs.- Income Tax Officer,………………………......Respondent Ward-6(1), Patna, Lok Nayak Jay Prakash Bhawan, Dak Bunglow Road, Patna-800001, Bihar

Section 115BSection 142(1)Section 143(1)Section 143(2)Section 272A(1)(d)Section 69A

normal rate of tax and add to the total income of the assessee, but not under section 115BBE. 7.1. So far as the interest under section 234B is concerned, proportionately levying interest will be made. 6 Vijaya Singh Therefore, the ground raised by the assessee is partly allowed

Shell Information Technology International Bv, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation )-4(2)(1), Mumbai

ITA 1750/MUM/2025[2022-23]Status: DisposedITAT Mumbai28 Jul 2025AY 2022-23

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI PRABHASH SHANKAR (Accountant Member)

For Appellant: Shri Madhur AgarwalFor Respondent: Shri Satya Pal Kumar
Section 143(3)Section 144C(13)Section 144C(5)Section 2(24)Section 234BSection 270A

Erred in not granting the TDS credit of Rs.2,06,98,133 without appreciating the facts and circumstance of the case. Interest under section 234B of the Act 10. Erred in levying interest of Rs.19,84,99,072 under section 234B of the Act without appreciating the facts and circumstance ... allowed for statistical purposes. Ground No. 10 & 11 12. Ground Nos. 10 & 11 raised by the Assessee pertains to levy of interest under Section 234B of the Act, respectively. Both the grounds are disposed off as being consequential in nature. 21 Ground No. 12 13. Ground No. 12 pertains

Portescap India Private Limited, Mumbai vs. DCIT Circle 2(3)(1), Mumbai

In the result the appeal filed by the assessee stands partly allowed

ITA 6749/MUM/2024[2021-22]Status: DisposedITAT Mumbai28 Jul 2025AY 2021-22

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

Section 143(3)Section 153Section 92C(3)

after considering the reliefs to be granted by your Honour in your Appellate Order 8. Ground No.8: Incorrect computation of interest under Section 234B of the Act On the facts and in the circumstances of the case and in law, the Ld. AO erred in computing and levying interest

Sri Lanka Cricket, Sri Lanka vs. Assistant Commissioner of Income Tax (International Tax) Circle- 3 (1)(2), New Delhi

ITA 1603/DEL/2025[2018-19]Status: DisposedITAT Delhi28 Jul 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Section 14Section 147Section 148Section 148ASection 154Section 234ASection 234BSection 270A

facts and in circumstances of the case and in law, the learned AO has erred in levying interest under Section 234B of the Act amounting to INR 9,99,30,694. 6. On the facts and in circumstances of the case and in law, the learned AO has erred

Celestial Aviation Trading 100 Limited, Ireland vs. ACIT Int. Tax. Circle 1(2)(1) New Delhi, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 1616/DEL/2025[2022-2023]Status: DisposedITAT Delhi25 Jul 2025AY 2022-2023
Section 143(2)Section 144C(1)

pressed. 25. In ground no 6 of appeal, the assessee has assailed charging of interest u/s. 234B of the Act. The charging of interest under section 234B of the Act is consequenital, hence, ground no. 6 of appeal is dismissed. 26. In ground no. 6.1 of appeal, the assessee