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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

Arun Bansal, Delhi vs. ACIT Central Circle 20, Delhi

In the result, appeal is allowed

ITA 2615/DEL/2022[2019-20]Status: DisposedITAT Delhi29 May 2023AY 2019-20

Bench: Shri G.S. Pannu & Shri Saktijit Deyassessment Year: 2019-20 Arun Bansal, 77, Shivam Versus Acit, Central Circle-20, Apartment, Sector-15, Rohini, Delhi. Delhi. Pan: Aagpb3126N (Appellant) (Respondent)

For Appellant: Sh. Somil Aggarwal, Advocate &For Respondent: Ms. Sapna Bhatia, CIT-DR
Section 132Section 132BSection 234B

should have adjusted the self assessment tax payable from the cash seized in terms with section 132B of the Act. In that case, interest under section 234B would not have been levied. Further, he submitted, under identical facts and circumstances, in case of the assessee’s own brother, interest charged

Umberto Ceramics Int P.Ltd, Mumbai vs. CIT (A) NFAC, Delhi

Appeal are dismissed

ITA 1661/MUM/2021[2017-18]Status: DisposedITAT Mumbai24 May 2023AY 2017-18
For Appellant: NoneFor Respondent: Shri Sridhar Govind Menon
Section 143(1)Section 154Section 2(24)(x)Section 36(1)(iv)Section 36(1)(va)Section 43B

Appellant is allowed for statistical purposes. Ground No. 4 11. Ground No. 4 raised by the Appellant is directed against the levy of interest under Section 234B of the Act. According to the Appellant interest under Section 234B of Act has been incorrectly been 5 ITA No.1662//Mum/2021 (Assessment Year ... computed and charged at INR 16,07,557/- instead of INR 13,75,038/-. The Assessing Officer is directed to re-compute interest under Section 234B of the Act as per law after taking into account the impact of adjudication of Ground No. 3 above. In terms of the aforesaid

Ubs Ag, Mumbai vs. DCIT (It) 4(3)(1), Mumbai

In the result, the appeals of assesse are partly allowed

ITA 5122/MUM/2017[2013-14]Status: DisposedITAT Mumbai24 May 2023AY 2013-14

Bench: Shri Aby T Varkey & Shri Amarjit Singhita Nos.2261 & 5122/Mum/2017 (A.Y. 2012-13 & 2013-14) Ubs Ag Vs. Deputy Commissioner Of Level 3, 2 North Avenue Income Tax (It)-4(3)(1) Maker Maxity, Bandra Air India Building, Kurla Complex, Bandra Nariman Point East, Mumbai – 400 051 Mumbai स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaacu5003G Appellant .. Respondent

For Appellant: Dhanesh Bafna &For Respondent: Manoj Kumar
Section 234BSection 37(1)

facts and circumstances of the case and in law, the Ld DRP erred in confirming the action of the Ld. AO in levying interest under section 234B and 234C of the Act. It is prayed that the adjustment be deleted The Grounds stated above are independent of, and without prejudice

Ubs Ag, Mumbai vs. DCIT (It) 4(3)(1), Mumbai

In the result, the appeals of assesse are partly allowed

ITA 2261/MUM/2017[2012-13]Status: DisposedITAT Mumbai24 May 2023AY 2012-13

Bench: Shri Aby T Varkey & Shri Amarjit Singhita Nos.2261 & 5122/Mum/2017 (A.Y. 2012-13 & 2013-14) Ubs Ag Vs. Deputy Commissioner Of Level 3, 2 North Avenue Income Tax (It)-4(3)(1) Maker Maxity, Bandra Air India Building, Kurla Complex, Bandra Nariman Point East, Mumbai – 400 051 Mumbai स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaacu5003G Appellant .. Respondent

For Appellant: Dhanesh Bafna &For Respondent: Manoj Kumar
Section 234BSection 37(1)

facts and circumstances of the case and in law, the Ld DRP erred in confirming the action of the Ld. AO in levying interest under section 234B and 234C of the Act. It is prayed that the adjustment be deleted The Grounds stated above are independent of, and without prejudice

Owens Corning (Singapore) Pvt Limited, Mumbai vs. The Dy Comm of Income Tax (International Tax), Circle -3(2)(2), Mumbai

In the result, appeal of assessee is allowed

ITA 377/MUM/2023[2020-21]Status: DisposedITAT Mumbai22 May 2023AY 2020-21

Bench: Shri B.R. Baskaran & Shri Pavan Kumar Gadaleowens Corning Inc., Dy.Cit C/O-Owens Corning (International Tax), बनाम/ (India) Pvt. Ltd., 7Th Circle-3(2)(2), Vs. Floor, Alpha Building Air India Building, Hiranandani Gardens Nariman Point, Powai, Mumbai-400076. Mumbai-400021. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaaco3242R (""थ" / Respondent) (अपीलाथ" /Appellant) अपीलाथ" ओर से / Appellant By : Shri Sandeep Bhalla.Ar ""थ" की ओर से/Respondent By : Shri Soumendu Kumar Dash.Dr सुनवाई की तारीख / Date Of Hearing 10/05/2023 घोषणा की तारीख /Date Of Pronouncement 22/05/2023 आदेश / Order Per Pavan Kumar Gadale - Jm: The Assessee Has Filed The Appeal Against The Order Of Assessing Officer (“Ao”) Passed Under Section 143(3)R.W.S144C(13) Of The Income Tax Act, 1961 (“The Act”) In Pursuance To The Directions Of Ld. Dispute Resolution Panel (“Drp”) U/S 144C(5) Of The Act Dated 28.11.2022. 2. The Assessee Has Raised Following Grounds Of Appeal:- 1.0 “Re: Treating Fabrication Charges Received As 'Fees For Technical Services': 1

For Appellant: Shri Sandeep Bhalla.ARFor Respondent: Shri Soumendu Kumar Dash.DR
Section 115ASection 143(2)Section 143(3)Section 144C(5)Section 234BSection 9(1)(vii)Section 90(2)

erroneous and illegal. 2.3 The Appellant submits that the AO be directed to re-compute the tax liability accordingly. 3.0 Re: Levy of interest under section 234B of the Income-tax Act, 1961: 3.1 The AO has erred in levying interest under section 234B of the Income ... Appellant submits that considering the facts and circumstances of the case and the law prevailing on the subject, no interest under section 234B is leviable and the stand taken by the AO in this regard is misconceived, incorrect, erroneous and illegal. ITA.NO.377/Mum/23 Owens-Corning(Singapore

I G International Pvt Ltd., Navi Mumbai vs. ACIT, CC-1(3), Mumbai

In the result, the appeal vide ITA No

ITA 146/MUM/2023[2015-16]Status: DisposedITAT Mumbai15 May 2023AY 2015-16

Bench: Shri Vikas Awasthy & Shri Amarjit Singhita Nos. 142 To 146/Mum/2023 (A.Ys.2013-14, 2015-16, 2016-17, 2017-18 & 2020-21) I.G. International Private Vs. Acit, Central Circle-1(3) Limited, 802, 8Th Floor, 9Th Floor, Pratishtha Akshar Bluechip Bhavan, M.K. Road, Building, Thane Belapur Mumbai - 400020 Road, Turbhe, Navi Mumbai – 400705 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aacci2508Q Appellant .. Respondent Appellant By : Ashok Mehta & Dipesh Vora Respondent By : V.S. Mahajan Date Of Hearing 20.04.2023 Date Of Pronouncement 15.05.2023 आदेश / O R D E R Per Amarjit Singh (Am): All These 5 Appeals Filed By The Assesse Against Two Different Combined Orders Of Ld. Cit(A) Are Based On Identical Fact & Similar Issue, Therefore, For The Sake Convenience All These Appeals Are Adjudicated Together By Taking The Ita No. 146/Mum/2023 As A Lead Case & Its Finding Will Be Applied Mutatis Mutandis To The Other Appeals Wherever Applicable. “1. The Learned Assessing Officer, Erred In Reopening Assessment Under Section 147 Without Jurisdiction Based On Surmises & Conjectures. Learned Cit(A)-47 Erred In Confirming The Same.

For Appellant: Ashok Mehta &For Respondent: V.S. Mahajan
Section 133ASection 143(3)Section 147Section 148Section 234B

disallowance of employee's contribution of PF and ESIC of Rs.13,94,845/-. 5. The learned CIT(A) erred in confirming the interest under section 234B of Rs.3,16,033/-. The assessee craves to leave to add, alter and amend any of the grounds of appeal.” 2. The facts

I G. International P Ltd., Navi Mumbai vs. ACIT, CC-1(3), Navi Mumbai

In the result, the appeal vide ITA No

ITA 145/MUM/2023[2013-14]Status: DisposedITAT Mumbai15 May 2023AY 2013-14

Bench: Shri Vikas Awasthy & Shri Amarjit Singhita Nos. 142 To 146/Mum/2023 (A.Ys.2013-14, 2015-16, 2016-17, 2017-18 & 2020-21) I.G. International Private Vs. Acit, Central Circle-1(3) Limited, 802, 8Th Floor, 9Th Floor, Pratishtha Akshar Bluechip Bhavan, M.K. Road, Building, Thane Belapur Mumbai - 400020 Road, Turbhe, Navi Mumbai – 400705 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aacci2508Q Appellant .. Respondent Appellant By : Ashok Mehta & Dipesh Vora Respondent By : V.S. Mahajan Date Of Hearing 20.04.2023 Date Of Pronouncement 15.05.2023 आदेश / O R D E R Per Amarjit Singh (Am): All These 5 Appeals Filed By The Assesse Against Two Different Combined Orders Of Ld. Cit(A) Are Based On Identical Fact & Similar Issue, Therefore, For The Sake Convenience All These Appeals Are Adjudicated Together By Taking The Ita No. 146/Mum/2023 As A Lead Case & Its Finding Will Be Applied Mutatis Mutandis To The Other Appeals Wherever Applicable. “1. The Learned Assessing Officer, Erred In Reopening Assessment Under Section 147 Without Jurisdiction Based On Surmises & Conjectures. Learned Cit(A)-47 Erred In Confirming The Same.

For Appellant: Ashok Mehta &For Respondent: V.S. Mahajan
Section 133ASection 143(3)Section 147Section 148Section 234B

disallowance of employee's contribution of PF and ESIC of Rs.13,94,845/-. 5. The learned CIT(A) erred in confirming the interest under section 234B of Rs.3,16,033/-. The assessee craves to leave to add, alter and amend any of the grounds of appeal.” 2. The facts

I G International Pvt Ltd., Navi Mumbai vs. ACIT, CC-1(3), Mumbai

In the result, the appeal vide ITA No

ITA 144/MUM/2023[2016-17]Status: DisposedITAT Mumbai15 May 2023AY 2016-17

Bench: Shri Vikas Awasthy & Shri Amarjit Singhita Nos. 142 To 146/Mum/2023 (A.Ys.2013-14, 2015-16, 2016-17, 2017-18 & 2020-21) I.G. International Private Vs. Acit, Central Circle-1(3) Limited, 802, 8Th Floor, 9Th Floor, Pratishtha Akshar Bluechip Bhavan, M.K. Road, Building, Thane Belapur Mumbai - 400020 Road, Turbhe, Navi Mumbai – 400705 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aacci2508Q Appellant .. Respondent Appellant By : Ashok Mehta & Dipesh Vora Respondent By : V.S. Mahajan Date Of Hearing 20.04.2023 Date Of Pronouncement 15.05.2023 आदेश / O R D E R Per Amarjit Singh (Am): All These 5 Appeals Filed By The Assesse Against Two Different Combined Orders Of Ld. Cit(A) Are Based On Identical Fact & Similar Issue, Therefore, For The Sake Convenience All These Appeals Are Adjudicated Together By Taking The Ita No. 146/Mum/2023 As A Lead Case & Its Finding Will Be Applied Mutatis Mutandis To The Other Appeals Wherever Applicable. “1. The Learned Assessing Officer, Erred In Reopening Assessment Under Section 147 Without Jurisdiction Based On Surmises & Conjectures. Learned Cit(A)-47 Erred In Confirming The Same.

For Appellant: Ashok Mehta &For Respondent: V.S. Mahajan
Section 133ASection 143(3)Section 147Section 148Section 234B

disallowance of employee's contribution of PF and ESIC of Rs.13,94,845/-. 5. The learned CIT(A) erred in confirming the interest under section 234B of Rs.3,16,033/-. The assessee craves to leave to add, alter and amend any of the grounds of appeal.” 2. The facts

I G International Pvt Ltd., Mumbai vs. Assistant Commissioner of Income Tax- Central Circle-1(3), Mumbai

In the result, the appeal vide ITA No

ITA 143/MUM/2023[2020-21]Status: DisposedITAT Mumbai15 May 2023AY 2020-21

Bench: Shri Vikas Awasthy & Shri Amarjit Singhita Nos. 142 To 146/Mum/2023 (A.Ys.2013-14, 2015-16, 2016-17, 2017-18 & 2020-21) I.G. International Private Vs. Acit, Central Circle-1(3) Limited, 802, 8Th Floor, 9Th Floor, Pratishtha Akshar Bluechip Bhavan, M.K. Road, Building, Thane Belapur Mumbai - 400020 Road, Turbhe, Navi Mumbai – 400705 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aacci2508Q Appellant .. Respondent Appellant By : Ashok Mehta & Dipesh Vora Respondent By : V.S. Mahajan Date Of Hearing 20.04.2023 Date Of Pronouncement 15.05.2023 आदेश / O R D E R Per Amarjit Singh (Am): All These 5 Appeals Filed By The Assesse Against Two Different Combined Orders Of Ld. Cit(A) Are Based On Identical Fact & Similar Issue, Therefore, For The Sake Convenience All These Appeals Are Adjudicated Together By Taking The Ita No. 146/Mum/2023 As A Lead Case & Its Finding Will Be Applied Mutatis Mutandis To The Other Appeals Wherever Applicable. “1. The Learned Assessing Officer, Erred In Reopening Assessment Under Section 147 Without Jurisdiction Based On Surmises & Conjectures. Learned Cit(A)-47 Erred In Confirming The Same.

For Appellant: Ashok Mehta &For Respondent: V.S. Mahajan
Section 133ASection 143(3)Section 147Section 148Section 234B

disallowance of employee's contribution of PF and ESIC of Rs.13,94,845/-. 5. The learned CIT(A) erred in confirming the interest under section 234B of Rs.3,16,033/-. The assessee craves to leave to add, alter and amend any of the grounds of appeal.” 2. The facts

I G International Pvt Ltd., Mumbai vs. Assistant Commissioner of Income Tax- Central Circle-1(3), Mumbai

In the result, the appeal vide ITA No

ITA 142/MUM/2023[2017-18]Status: DisposedITAT Mumbai15 May 2023AY 2017-18

Bench: Shri Vikas Awasthy & Shri Amarjit Singhita Nos. 142 To 146/Mum/2023 (A.Ys.2013-14, 2015-16, 2016-17, 2017-18 & 2020-21) I.G. International Private Vs. Acit, Central Circle-1(3) Limited, 802, 8Th Floor, 9Th Floor, Pratishtha Akshar Bluechip Bhavan, M.K. Road, Building, Thane Belapur Mumbai - 400020 Road, Turbhe, Navi Mumbai – 400705 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aacci2508Q Appellant .. Respondent Appellant By : Ashok Mehta & Dipesh Vora Respondent By : V.S. Mahajan Date Of Hearing 20.04.2023 Date Of Pronouncement 15.05.2023 आदेश / O R D E R Per Amarjit Singh (Am): All These 5 Appeals Filed By The Assesse Against Two Different Combined Orders Of Ld. Cit(A) Are Based On Identical Fact & Similar Issue, Therefore, For The Sake Convenience All These Appeals Are Adjudicated Together By Taking The Ita No. 146/Mum/2023 As A Lead Case & Its Finding Will Be Applied Mutatis Mutandis To The Other Appeals Wherever Applicable. “1. The Learned Assessing Officer, Erred In Reopening Assessment Under Section 147 Without Jurisdiction Based On Surmises & Conjectures. Learned Cit(A)-47 Erred In Confirming The Same.

For Appellant: Ashok Mehta &For Respondent: V.S. Mahajan
Section 133ASection 143(3)Section 147Section 148Section 234B

disallowance of employee's contribution of PF and ESIC of Rs.13,94,845/-. 5. The learned CIT(A) erred in confirming the interest under section 234B of Rs.3,16,033/-. The assessee craves to leave to add, alter and amend any of the grounds of appeal.” 2. The facts

Cnh Industrial (India) Private Limited, Mumbai vs. The Assistant Commissioner of Income Tax, Centre Circle 6(3), Mumbai

In the result appeal of the assessee is partly allowed

ITA 1890/MUM/2022[2018-19]Status: DisposedITAT Mumbai15 May 2023AY 2018-19

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm Cnh Industrial (Ind) Pvt. Ltd Level04, Rectangle-1, D4 Acit, Central Circle 6(3) District Center, Commercial Mumbai Vs. Complex Saket, South Delhi, Delhi 110017 (Appellant) (Respondent) Pan No. Aaci3922Q

For Appellant: Shri. Ajit Jain, ARFor Respondent: Ms. Samruddhi Hande, DR
Section 234BSection 92C

against the returned income of Rs. 1,91,96,80,300 under the normal provisions of the Act Levying income tax including interest under Section 234B of the Act and raising a net demand payable of Rs. 18,09,08,820 upon the Appellant. II. Transfer Pricing Grounds- Adjustment ... under section 234B of the Act 8.1 On the facts and in the circumstances of the case, the AO has erred in levying interest under section 234B of the Act which is consequential in nature. 8.2 The Appellant submits that it is not liable to pay any interest under Section

Shilpa Prabhakar Kulkarni, Mumbai vs. DCIT, CPC, Bengaluru

In the result, the appeal of the assessee is allowed partly for In the result, the appeal of the assessee is allowed partly for In the result, the appeal of the assessee is allowed partly for stati...

ITA 387/MUM/2023[2017-18]Status: DisposedITAT Mumbai11 May 2023AY 2017-18

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2017-2018 Shilpa Prabhakar Kulkarni, Dcit Centralized Processing 3 Neel Sagar, 1280 Prabhadevi Centre, Seaface Prabhadevi, Vs. Bengaluru-560 500. Mumbai-400025. Pan No. Brhpk 8129 D Appellant Respondent Assessee By : Ms. Chandni Shah & Kinjal Patel Revenue By : Mr. A.N. Bhalekar, Dr Date Of Hearing : 03/05/2023 : Date Of Pronouncement 11/05/2023 Order

For Appellant: Ms. Chandni Shah & Kinjal PatelFor Respondent: Mr. A.N. Bhalekar, DR
Section 154Section 234BSection 234C

facts and circumstances of the case and in law, the NFAC erred in levying additional the NFAC erred in levying additional interest under interest under Section 234B of the Act. Section 234B of the Act. The Appellant prays that the additional interest levied The Appellant prays that the additional interest

Unilever India Exports Ltd., Mumbai vs. DCIT, -CC 5(3), Mumbai

In the result, appeal of the assessee for AY 2017-18 and 2018-19 are allowed

ITA 2108/MUM/2022[2017-18]Status: DisposedITAT Mumbai11 May 2023AY 2017-18

Bench: Amit Shukla () & Ms. Padmavathy S. ()

Section 143(3)Section 144C(13)Section 14ASection 234BSection 270A

payment of central fees Grounds 8 & 9 : Disallowance under section 14A Grounds 10-13: Disallowance of ESOP expenses. Ground 14 : Excess levy of interest under section 234B & 234D Ground 15 : Initiation of penalty under section 270A 7. TP adjustment towards payment of central services (Ground No.3

Unilever India Exports Limited, Mumbai vs. ACIT - Central Circle - 5(3), Mumbai

In the result, appeal of the assessee for AY 2017-18 and 2018-19 are allowed

ITA 2107/MUM/2022[2018-19]Status: DisposedITAT Mumbai11 May 2023AY 2018-19

Bench: Amit Shukla () & Ms. Padmavathy S. ()

Section 143(3)Section 144C(13)Section 14ASection 234BSection 270A

payment of central fees Grounds 8 & 9 : Disallowance under section 14A Grounds 10-13: Disallowance of ESOP expenses. Ground 14 : Excess levy of interest under section 234B & 234D Ground 15 : Initiation of penalty under section 270A 7. TP adjustment towards payment of central services (Ground No.3

Mrs. Divyesh Ambalal Shah, Mumbai vs. ACIT-27(1), Navimumbai

ITA 629/MUM/2023[2011-12]Status: DisposedITAT Mumbai08 May 2023AY 2011-12
Section 143(3)Section 147Section 148Section 234BSection 68

brokerage for generating the alleged bogus accommodation entry of Rs.2,77,800/-. 8. The L.d. CIT(A) erred in upholding the levy of interest under section 234B and 234C of the Act and the same ought to be deleted. 9. The appellant prays that the Assessing Officer be directed

Goldman Sachs & Co., Mumbai vs. Dy CIT (International Taxation)-2(3)(2), Mumbai

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

ITA 1264/MUM/2021[2017-18]Status: DisposedITAT Mumbai08 May 2023AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

For Appellant: Shri Madhur AgarwalFor Respondent: Shri Soumendu Kumar Dash
Section 143(3)Section 144C(13)Section 144C(5)Section 234A

assessee‟s appeal is allowed for statistical purposes. 33. Ground no.6, raised in assessee‟s appeal, is pertaining to the levy of interest under section 234B of the Act, which is consequential in nature. Therefore, ground no.6 is allowed for statistical purposes. Goldman Sachs & Co. ITA no.401/Mum./2018 ITA no.7490/Mum

Goldman Sachs & Co., Mumbai vs. DCIT- 2(3)(2), Mumbai

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

ITA 6005/MUM/2019[2015-16]Status: DisposedITAT Mumbai08 May 2023AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

For Appellant: Shri Madhur AgarwalFor Respondent: Shri Soumendu Kumar Dash
Section 143(3)Section 144C(13)Section 144C(5)Section 234A

assessee‟s appeal is allowed for statistical purposes. 33. Ground no.6, raised in assessee‟s appeal, is pertaining to the levy of interest under section 234B of the Act, which is consequential in nature. Therefore, ground no.6 is allowed for statistical purposes. Goldman Sachs & Co. ITA no.401/Mum./2018 ITA no.7490/Mum

Goldman Sachs & Co, Mumbai vs. DCIT (It)-2(3)(2), Mumbai

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

ITA 7490/MUM/2018[2014-15]Status: DisposedITAT Mumbai08 May 2023AY 2014-15

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

For Appellant: Shri Madhur AgarwalFor Respondent: Shri Soumendu Kumar Dash
Section 143(3)Section 144C(13)Section 144C(5)Section 234A

assessee‟s appeal is allowed for statistical purposes. 33. Ground no.6, raised in assessee‟s appeal, is pertaining to the levy of interest under section 234B of the Act, which is consequential in nature. Therefore, ground no.6 is allowed for statistical purposes. Goldman Sachs & Co. ITA no.401/Mum./2018 ITA no.7490/Mum

Goldman Sachs & Company, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation) 2(3)(2), Mumbai

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

ITA 401/MUM/2018[2013-14]Status: DisposedITAT Mumbai08 May 2023AY 2013-14

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

For Appellant: Shri Madhur AgarwalFor Respondent: Shri Soumendu Kumar Dash
Section 143(3)Section 144C(13)Section 144C(5)Section 234A

assessee‟s appeal is allowed for statistical purposes. 33. Ground no.6, raised in assessee‟s appeal, is pertaining to the levy of interest under section 234B of the Act, which is consequential in nature. Therefore, ground no.6 is allowed for statistical purposes. Goldman Sachs & Co. ITA no.401/Mum./2018 ITA no.7490/Mum

Vodafone India Ltd, Mumbai vs. DCIT Cir 7(3), Mumbai

In the result, appeal by the assessee is partly allowed, in the terms aforesaid

ITA 6718/MUM/2012[2008-09]Status: DisposedITAT Mumbai08 May 2023AY 2008-09

Bench: Shri Vikas Awasthy & Shri M. Balaganeshआअसं. 6718/Mum/2012 (िन.व. 2008-09) Vodafone India Ltd. (Formerly Known As ‘Vodafone Essar Limited’) Peninsula Corporate Park, Ganpatrao Kadam Marg, Lower Parel, Mumbai – 400 013. ...... अपीलाथ"/Appellant Pan:Aaach-5332-B बनाम Vs. Dy. Commissioner Of Income Tax 7(3), ..... ""तवाद"/Respondent Mumbai. अपीलाथ" "वारा/ Appellant By :Shri Salil Kapoor, Advocate With S/Shri Vibhu Jain & A.K.Jawadwala ""तवाद" "वारा/Respondent By :Shri Anand Mohan, Cit-Dr

For Appellant: Shri Salil Kapoor, Advocate with S/Shri Vibhu Jain and A.K.JawadwalaFor Respondent: Shri Anand Mohan, CIT-DR
Section 115JSection 143(3)Section 14ASection 234BSection 40Section 80I

related costs of seconded employees; Ground No.14: Non-grant of full credit in respect of Tax Deducted at Source; Ground No.15: Levy of interest under section 234B and 234C of the Act. 3. Shri Salil Kapoor appearing on behalf of the assessee submits at the outset that the facts