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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

Shri Sheshavtar 1008 Shri Kallaji Vedpith Evam Shodh Sansthan, Nimbahera, Chittorgarh vs. ITO Exemption Ward, Udaipur, Aaykar Bhawan

In the result, appeal of the assessee is partly allowed

ITA 268/JODH/2024[2017-18]Status: DisposedITAT Jodhpur01 Apr 2025AY 2017-18

Bench: DR. MITHA LAL MEENA (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Sunil Surana, CA &For Respondent: Shri Karni Dan, Addl. CIT, Sr.DR
Section 115BSection 12ASection 142Section 143(1)Section 143(2)Section 234BSection 234DSection 250

allowed. Ground No. 5 That on the facts and in the circumstances of the case, the Ld CIT (A) has confirmed charge of interest under section 234B and under Section 234D of the Income Tax Act 1961 amounting to Rs 11,82,918/- and Rs 4,370/- respectively which

M/S. Rotary Club of Worli Bombay Trust, Mumbai vs. ITO, Exemption Ward 2(2), Mumbai

ITA 257/MUM/2025[2015-16]Status: DisposedITAT Mumbai28 Mar 2025AY 2015-16

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SMT RENU JAUHRI (Accountant Member)

For Appellant: Shri Hitesh JainFor Respondent: Shri R. R. Makwana
Section 11Section 143(3)Section 234BSection 250

ought to have granted TDS credit of Rs.50,480/- to the appellant. 7. The Ld. AO has erred in levying interest under section 234B of the Act amounting to Rs.8.55.638/-, On the facts and circumstance of the case and in law, the interest levied under section 234B ought

Sama Jewellery Private Ltd, Mumbai vs. DCIT, Circle 8(1)(1), Mumbai

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

ITA 3920/MUM/2024[2017-18]Status: DisposedITAT Mumbai28 Mar 2025AY 2017-18

Bench: SHRI VIKRAM SINGH YADAV (Accountant Member), SHRI RAHUL CHAUDHARY (Judicial Member)

Section 143(3)Section 234BSection 250Section 271ASection 68Section 69C

facts and circumstances of the case and law, the Ld. CIT(A) erred in confirming the action of Ld AO in levying interest under section 234B and 234C of the Income Tax Act, 1961. 7. On the facts and circumstances of the case and law, the Ld. CIT(A) erred

DCIT-CC-5(3), Mumbai vs. Indiafirst Life Insurance Company Limited, Mumbai

Appeal is dismissed, accordingly

ITA 3827/MUM/2024[2017-18]Status: DisposedITAT Mumbai28 Mar 2025AY 2017-18

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI OMKARESHWAR CHIDARA (Accountant Member)

For Appellant: Shri Farookh IraniFor Respondent: Shri R.A.Dhyani
Section 10Section 10(34)Section 143(3)Section 14ASection 234BSection 250Section 270Section 44

IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, MUMBAI SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI OMKARESHWAR CHIDARA, ACCOUNTANT MEMBER Deputy

Dy.Commissioner of Income Tax, Central Circle-1, Aurangabad vs. Parth Multitrade Pvt Ltd, Jalna

In the result, the appeal filed by the Revenue and the CO filed by the assessee are allowed for statistical purposes

ITA 1345/PUN/2024[2008-2009]Status: DisposedITAT Pune26 Mar 2025AY 2008-2009

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2008-09

For Appellant: Shri Anand PartaniFor Respondent: Shri Ajay Kumar Keshari - CIT
Section 143(1)Section 143(3)Section 147Section 148Section 151Section 151(1)Section 68

identity, creditworthiness and genuineness of the shareholders. Therefore, the same may be deleted. d. The learned AO was not justified in charging interest under section 234B of the Income Tax Act, 1961. 5 CO No.28/PUN/2024 e. The learned AO was not justified in initiating penalty proceedings under section

Standard and Poors South Asia Services Private Limited, New Delhi vs. ACIT, New Delhi

In the result, appeal filed by the assessee is allowed

ITA 3792/DEL/2024[2020-21]Status: DisposedITAT Delhi21 Mar 2025AY 2020-21

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI VIMAL KUMAR (Judicial Member)

For Appellant: Ms. Ananya Kapoor, AdvocateFor Respondent: Shri S.K. Jhadav, CIT DR
Section 143(3)Section 144Section 144C(13)Section 234BSection 928Section 92C

adjustment is allowable, no further adjustment on account of receivables is required/mandated in law. 3. The learned AO has erred in levying consequential interest under section 234B, 234C of the Act.” 2. In the grounds of appeal, a solitary issue raised by the assessee is levy of interest

At & T Global Network Services India Private Ltd., Gurgaon vs. ACIT Circle-1(1), New Delhi

ITA 1576/DEL/2022[2018-19]Status: DisposedITAT Delhi21 Mar 2025AY 2018-19

Bench: Sh. Satbeer Singh Godara & Sh. Avdhesh Kumar Mishra

For Appellant: Sh. K. M. Gupta, Adv. &For Respondent: Sh. Dharm Veer Singh, CIT-DR
Section 143(3)

erred in not granting complete credit of taxes deducted at source to the Appellant. 9. Levy of interest under section 234B and 234C of the Act 6 SA No. 425/Del/2024 AT&T Global Network Services India Pvt. Ltd. 9.1. On the facts, in the circumstances of the case ... erred in incorrectly charging interest under section 234B and 234C of the Act. 10. Initiation of penalty proceedings 10.1. On the facts, in the circumstances of the case and in law, the Ld. AO erred in initiating penalty proceedings under section 270A of the Act against the Appellant on account

Pooja Grover, Allahabad vs. DCIT, Cir-2, Allahabad

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

ITA 140/ALLD/2024[2017-18]Status: DisposedITAT Allahabad20 Mar 2025AY 2017-18

Bench: Shri Subhash Malguria & Shri Nikhil Choudhary

Section 142(1)Section 143(2)Section 143(3)Section 234BSection 251Section 69A

payments have been made by appellant duly verifiable from her books of account. 9. BECAUSE the appellant denies for levy of interest under section 234B of the Income Tax Act, 1961. 10. BECAUSE the order appealed against is contrary to the facts, law and principle of natural justice

Credit Agricole Corporate and Investment Bank, Mumbai vs. The Dy-CIT (Int. Taxation)-2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 749/MUM/2022[2017-18]Status: DisposedITAT Mumbai20 Mar 2025AY 2017-18

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

Section 143(3)

this order. The grounds raised by the assessee are partly allowed. 42. Ground No. 22 & 23 is with regard to levy of interest under section 234B and penalty which are consequential not warranting any separate adjudication. ITA No. 1839/Mum/2015 – Revenue's Appeal 43. The ground raised by the Revenue pertains ... India at 50% of commission Ground No.14 & Ground No.17 earned by Hong Kong Branch on ECB to 15 & 18 Indian borrowers Levy of interest under section 234B Ground No.19 Ground No.22 Levy of penalty under section 271(1)(c) Ground No.20 Ground No.23 45. From the above table

Credit Agricole Corporate & Investment Bank, Mumbai vs. The Dy.CIT of Income Tax (Internationsl Taxation) -2(1) (1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1234/MUM/2022[2018-19]Status: DisposedITAT Mumbai20 Mar 2025AY 2018-19

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

Section 143(3)

this order. The grounds raised by the assessee are partly allowed. 42. Ground No. 22 & 23 is with regard to levy of interest under section 234B and penalty which are consequential not warranting any separate adjudication. ITA No. 1839/Mum/2015 – Revenue's Appeal 43. The ground raised by the Revenue pertains ... India at 50% of commission Ground No.14 & Ground No.17 earned by Hong Kong Branch on ECB to 15 & 18 Indian borrowers Levy of interest under section 234B Ground No.19 Ground No.22 Levy of penalty under section 271(1)(c) Ground No.20 Ground No.23 45. From the above table

Credit Agricole Corporate & Investment Bank, Mumbai vs. The Jt CIT (International Taxationa), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1027/MUM/2021[2016-17]Status: DisposedITAT Mumbai20 Mar 2025AY 2016-17

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1165/Mum/2016 (Assessment Year: 2011-12) Dcit (International Taxation)- 1(1)(1), Room No. 114, 1St Floor, Scindia House, N.M. Marg, Ballard Estate, Mumbai-400038. Appellant) Vs. Credit Agricole Corporate & Investment Bank, 11Th & 12Th & 14Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent)

Section 143(3)

this order. The grounds raised by the assessee are partly allowed. 42. Ground No. 22 & 23 is with regard to levy of interest under section 234B and penalty which are consequential not warranting any separate adjudication. ITA No. 1839/Mum/2015 – Revenue's Appeal 43. The ground raised by the Revenue pertains ... income of Indian Branches Taxability in India at 50% of commission earned by Hong Kong Branch on ECB to Indian borrowers Levy of interest under section 234B Levy of penalty under section 271(1)(c) AY 2011-12 Ground No.1 AY 2010-11 Ground No.1 Ground No.2 & 3 Ground No.2

Credit Agricole Corporate and Investment Bank, Mumbai vs. ACIT (It) 2 (1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 458/MUM/2019[2014-15]Status: DisposedITAT Mumbai20 Mar 2025AY 2014-15

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) 2

Section 143(3)

this order. The grounds raised by the assessee are partly allowed. 42. Ground No. 22 & 23 is with regard to levy of interest under section 234B and penalty which are consequential not warranting any separate adjudication. ITA No. 1839/Mum/2015 – Revenue's Appeal 43. The ground raised by the Revenue pertains ... Kong Branch on ECB to Indian borrowers Ground No.14 & 15 Ground No.17 & 18 Ground No.19 Ground No.20 Ground No.22 Ground No.23 Levy of interest under section 234B Levy of penalty under section 271(1)(c) 45. From the above table it is clear that the grounds of the assessee

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 4652/MUM/2017[2013-14]Status: DisposedITAT Mumbai20 Mar 2025AY 2013-14

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As ‘Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent)

Section 143(3)

this order. The grounds raised by the assessee are partly allowed. 42. Ground No. 22 & 23 is with regard to levy of interest under section 234B and penalty which are consequential not warranting any separate adjudication. ITA No. 1839/Mum/2015 – Revenue's Appeal 43. The ground raised by the Revenue pertains ... India at 50% of commission earned by Hong Kong Branch on ECB to Indian borrowers Ground No.14 & 15 Ground No.17 & 18 Levy of interest under section 234B Ground No.19 Ground No.22 Levy of penalty under section 271(1)(c) Ground No.20 Ground No.23 45. From the above table

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 2313/MUM/2017[2012-13]Status: DisposedITAT Mumbai20 Mar 2025AY 2012-13

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As ‘Calyon Bank’) 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) 2

Section 143(3)

this order. The grounds raised by the assessee are partly allowed. 42. Ground No. 22 & 23 is with regard to levy of interest under section 234B and penalty which are consequential not warranting any separate adjudication. ITA No. 1839/Mum/2015 – Revenue's Appeal 43. The ground raised by the Revenue pertains ... income of Indian Branches Taxability in India at 50% of commission earned by Hong Kong Branch on ECB to Indian borrowers Levy of interest under section 234B Levy of penalty under section 271(1)(c) AY 2011-12 Ground No.1 AY 2010-11 Ground No.1 Ground No.2 & 3 Ground No.2

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1273/MUM/2016[2011-12]Status: DisposedITAT Mumbai20 Mar 2025AY 2011-12

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Credit Agricole Corporate & Investment Bank, Vs. 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Appellant) Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) 2

Section 143(3)

this order. The grounds raised by the assessee are partly allowed. 42. Ground No. 22 & 23 is with regard to levy of interest under Section 234B and penalty which are consequential not warranting any separate adjudication. ITA No. 1839/Mum/2015 – Revenue's Appeal 43. The ground raised by the Revenue pertains ... India at 50% of commission earned by Hong Kong Branch on ECB to Indian borrowers Ground No.14 & 15 Ground No.17 & 18 Levy of interest under Section 234B Ground No.19 Ground No.22 Levy of penalty under Section 271(1)(c) Ground No.20 Ground No.23 45. From the above table

DCIT (It) 2(1)(1), Mumbai vs. Credit Agricole Corporate and Investment Bank, Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1165/MUM/2016[2011-12]Status: DisposedITAT Mumbai20 Mar 2025AY 2011-12

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1165/Mum/2016 (Assessment Year: 2011-12) Dcit (International Taxation)- 1(1)(1), Room No. 114, 1St Floor, Scindia House, N.M. Marg, Ballard Estate, Mumbai-400038. Appellant) Vs. Credit Agricole Corporate & Investment Bank, 11Th & 12Th & 14Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent)

Section 143(3)

this order. The grounds raised by the assessee are partly allowed. 42. Ground No. 22 & 23 is with regard to levy of interest under Section 234B and penalty which are consequential not warranting any separate adjudication. ITA No. 1839/Mum/2015 – Revenue's Appeal 43. The ground raised by the Revenue pertains ... income of Indian Branches Taxability in India at 50% of commission earned by Hong Kong Branch on ECB to Indian borrowers Levy of interest under section 234B Levy of penalty under section 271(1)(c) AY 2011-12 Ground No.1 AY 2010-11 Ground No.1 Ground No.2 & 3 Ground No.2

ADIT (It) 1(2), Mumbai vs. Credit Agricole Corporate and Investment Bank, Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1839/MUM/2015[2010-11]Status: DisposedITAT Mumbai20 Mar 2025AY 2010-11

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

Section 143(3)

this order. The grounds raised by the assessee are partly allowed. 42. Ground No. 22 & 23 is with regard to levy of interest under section 234B and penalty which are consequential not warranting any separate adjudication. ITA No. 1839/Mum/2015 – Revenue's Appeal 43. The ground raised by the Revenue pertains ... India at 50% of commission Ground No.14 & Ground No.17 earned by Hong Kong Branch on ECB to 15 & 18 Indian borrowers Levy of interest under section 234B Ground No.19 Ground No.22 Levy of penalty under section 271(1)(c) Ground No.20 Ground No.23 45. From the above table

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1479/MUM/2015[2010-11]Status: DisposedITAT Mumbai20 Mar 2025AY 2010-11

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As ‘Calyon Bank’) 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent)

Section 143(3)

this order. The grounds raised by the assessee are partly allowed. 42. Ground No. 22 & 23 is with regard to levy of interest under Section 234B and penalty which are consequential not warranting any separate adjudication. ITA No. 1839/Mum/2015 – Revenue's Appeal 43. The ground raised by the Revenue pertains ... India at 50% of commission earned by Hong Kong Branch on ECB to Indian borrowers Ground No.14 & 15 Ground No.17 & 18 Levy of interest under section 234B Ground No.19 Ground No.22 Levy of penalty under section 271(1)(c) Ground No.20 Ground No.23 45. From the above table

Hanning Motors India Private Limited, Vadodara vs. The Dy.CIT, Circle-1(1)(1), Vadodara

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

ITA 1931/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad13 Mar 2025AY 2017-18
For Appellant: Revenue by
Section 143(3)Section 92C

providing setoff of MAT credit available as per provisions of section 115JAA of the Act. 10. The learned AO has erred in levying interest under section 234B of the Act of Rs.1,10,58,900/-. On the facts and in the circumstances of the case, interest under section 234B ... leviable, being consequential in nature. The Appellant denies its liability to pay interest under section 234B. Even otherwise the interest computed is excessive. The Appellant submits that each of the above grounds/ sub-grounds are independent and without prejudice to one another. The Appellant craves leave to add, alter, vary

ITO, Ward-2(1), Ludhiana vs. Ashwani Kumar Jain, Ludihana

In the result, appeal of the Revenue is dismissed

ITA 1083/CHANDI/2024[2022]Status: DisposedITAT Chandigarh12 Mar 2025

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Balbir Khanna, AdvocateFor Respondent: Shri Vivek Vardhan, Addl.CIT Sr.DR
Section 115BSection 142(1)Section 143(2)Section 69C

cited above and the discussion above, these grounds of appeal adduced by the appellant are upheld stands disposed off accordingly. Ground no. 13: Interest under section 234B and 234C Ground no. 13 relates to the interest levied upon the appellant under section 234B and 234C of the IT. Act. Since