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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

Unimed Technologies Limited, Panchmahal vs. The ACIT, Circle-2(1)(1), Vadodara

ITA 623/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad24 Jul 2025AY 2016-17

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2016-17 Unimed Technologies Limited Acit, Cir.2(1)(1) Survey No.22 & 22, Vs. Vadodara. Baska, Ujeti Halol Panchmahal Pan : Aaace 4022 B Asstt.Year : 2016-17 Acit, Cir.2(1)(1) Unimed Technologies Limited Vadodara. Vs. Survey No.22 & 22, Baska, Ujeti Halol Panchmahal Pan : Aaace 4022 B (Applicant) (Responent) : Shri Bandish Soparkar, Ar Assessee By : Shri Sher Singh, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 17/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 24/07/2025 आदेश आदेश/O R D E R आदेश आदेश

For Appellant: Shri Sher Singh, CIT-DR
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 234BSection 250Section 271(1)(b)Section 271(1)(c)Section 36(1)(iii)Section 37(1)

Being aggrieved, the assessee preferred an appeal before the CIT(A) where short grant of TDS of Rs.13,11,100/- and interest under section 234B of Rs.1,01,36,645/- were also disputed by the assessee. Claim for deduction of education cess of Rs.12,63,048/- under section ... Assessing Officer to rectify the computation of tax by granting due credit of TDS amounting to Rs.13,11,100/- and to recompute interest under section 234B of the Act after considering the corrected TDS credit. The CIT(A) also directed verification and appropriate rectification in respect of the short grant

Vindhya Trust, New Delhi vs. Deputy Commissioner of Income Tax, New Delhi

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

ITA 131/DEL/2025[2021-22]Status: DisposedITAT Delhi23 Jul 2025AY 2021-22

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanvindhya Trust, Vs. Dcit, Circle 49 (1), B – 60/61, C/O Bajaj Auto Limited, Delhi. Naraina Industrial Estate, Delhi – 110 028. (Pan : Aaatv0303K) (Appellant) (Respondent) Assessee By : Shri Mahender Gohel, Ca Revenue By : Shri Ramesh Chand, Sr. Dr Date Of Hearing : 13.05.2025 Date Of Order : 23.07.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Addl/Joint Commissioner Of Income-Tax (Appeals) – 3, Hyderabad [Hereinafter Referred To As ‘Ld. Jcit (A)] Dated 12.11.2024 For Assessment Year 2021-22 Raising Following Grounds Of Appeal :- “Ground 1 - Rate Of Tax: The Learned Commissioner Of Income Tax (Appeals) [Cit(A)] Has Erred In Upholding Levy Of Tax At Flat Rate Of30%, Instead Of Normal Slab Rates Applicable In The Case Of The Appellant. The Learned Cit(A) & The Learned Assessing Officer Failed To Appreciate That The Appellant Is An Association Of Persons (Aop)/Charitable Trust Not Claiming Benefits Of Section 11 Of The Act & Is Liable To Pay Tax At The Slab Rates Applicable In The Case Of An Individual, Etc. The Appellant Prays That The Learned Assessing Officer Be Directed To Re-Compute

For Appellant: Shri Mahender Gohel, CAFor Respondent: Shri Ramesh Chand, Sr. DR
Section 11Section 143(1)Section 167BSection 234BSection 234C

learned Assessing Officer be directed to re-compute the surcharge of the appellant as explained above and reduce the same accordingly. Ground 3 - INTEREST UNDER SECTION 234B & 234C: The learned CIT(A) erred in upholding interest charged under the provisions of Section 234B and 234C of the Act, while processing

Mobite Technologies Pvt. Ltd., Pune vs. ITO, Ward, 7(1), Pune

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

ITA 1258/PUN/2025[2021-22]Status: DisposedITAT Pune10 Jul 2025AY 2021-22

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं./Ita No.1258/Pun/2025 िनधा"रण वष" / Assessment Year: 2021-22 Mobite Technologies Private V The Income Tax Officer, Limited, S. Ward-7(1), Pune. A-701, Victoria Garden, Nagar Road, Kalyani Nagar, Pune – 411006. Maharashtra. Pan: Aafcm7197J Appellant/ Assessee Respondent / Revenue Assessee By Shri Abhay Avachat – Ar Revenue By Smt. Shilpa Nc – Addl.Cit(Dr) Date Of Hearing 03/07/2025 Date Of Pronouncement 10/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: The Assessee Has Filed An Appeal Against The Order Of Ld.Addl./Joint Commissioner Of Income Tax(Appeal)-10, Delhi Passed Under Section 250 Of The Income Tax Act, 1961 Dated 12.02.2025 For A.Y.2021-22, Emanating From The Order U/S.143(1) Of The Act. The Assessee Has Raised The Following Grounds Of Appeal : “1. The Ao Cpc Has Erred In Rejecting Concessional Rate Of Income Tax Of 22% Adopted By Assessee For Calculation Of Tax Liability As Per Itr U/S 115Baa & The Ld. Cit A Erred In Confirming The Same

Section 115Section 115BSection 115JSection 143Section 143(1)Section 234BSection 250

other relief as is available in the facts and circumstances of the case and in law. The CPC has erred in levying additional interest under section 234B, 234C in the intimation. The intimation has made certain adjustments which are not permissible under section 143(1) of the Act, therefore intimation

Sivakarthick Raman, Madurai vs. The Assistant Commissioner of Income Tax, International Taxation, Circle Madurai

In the result, the appeal of the assessee is allowed in terms of our above order

ITA 281/CHNY/2025[2022-23]Status: DisposedITAT Chennai07 Jul 2025AY 2022-23

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:281/Chny/2025 िनधा"रण वष" / Assessment Year: 2022-23 Sivakarthick Raman, The Assistant Commissioner Of 5/200, 2Nd Street, Alagupillai Nagar, Vs. Income Tax, T.Pudukudi, International Taxation Circle, Achampathu, Madurai. Madurai – 625 019. [Pan: Ajnpr-3214-R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Ms. Preeti Goel, Advocate ""थ" की ओर से/Respondent By : Ms. Anitha, Addl. C.I.T. सुनवाई की तारीख/Date Of Hearing : 21.04.2025 घोषणा की तारीख/Date Of Pronouncement : 07.07.2025 आदेश /O R D E R Per S. R. Raghunatha, Am:

For Appellant: Ms. Preeti Goel, AdvocateFor Respondent: Ms. Anitha, Addl. C.I.T
Section 143(3)Section 144C(13)Section 15Section 15(1)(a)Section 234BSection 234DSection 5(2)Section 5(2)(a)Section 9(1)(ii)Section 90

China by the Appellant. 5. The learned AO has in the facts and circumstances of the case and in law erred in levying interest under Section 234B and Section 234D of the Act amounting to INR 2,07,030. Any consequential relief, to which the Appellant may be entitled under