“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

Black Knight India Solutions Private Limited, Hyderabad vs. Assistant Commissioner of Income Tax, Circle-1(1)(2), Bangalore

In the result, the appeal filed by assessee stands allowed on ground no

ITA 230/BANG/2021[2016-17]Status: DisposedITAT Bangalore29 Apr 2022AY 2016-17

Bench: Shri. B.R. Baskaran & Smt. Beena Pillaiit(Tp)A No. 230/Bang/2021 Assessment Year : 2016-17 M/S. Black Knight India Solutions Pvt. Ltd., The Assistant 6-3-1192-2-1, Htc Commissioner Of Towers, Kundanbagh, Income Tax, Begumpet, Circle – 1(1)(2), Hyderabad, Vs. Bangalore. Telangana – 500 016. Pan: Aaccl2956K Appellant Respondent : Shri S.P. Chidambaram, Assessee By Advocate : Shri Sumer Singh Meena, Cit Revenue By Dr Date Of Hearing : 26-04-2022 Date Of Pronouncement : 29-04-2022 Order Per Beena Pillaipresent Appeal Arises Out Of The Final Assessment Order Dated 30.03.2021 Passed By The Ld.Ao In National E-Assessment For Assessment Year 2016-17 On Following Grounds Of Appeal: “1. That On The Facts & Circumstances Of The Case, The Final Assessment Order Dated 30 March 2021 (And Received By The Appellant On 30 March 2021) Passed By The Additional / Joint / Deputy / Assistant Commissioner Of Income Tax/ Income-Tax Officer, National E-Assessment

For Respondent: Shri S.P. Chidambaram

Section 144Section 144C(5)Section 92C

adjustment to the Appellant. 17. That on the facts and circumstances of the case and in law, the AO erred by calculating excess interest under section 234B of the Act. 18. That the consequential effect should be given to the liability of interest under section 234B and 234D

M/S. Bangalore Metro Rail Corporation Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle - 1(1)(2), Bangalore

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

ITA 1111/BANG/2019[2010-11]Status: DisposedITAT Bangalore29 Apr 2022AY 2010-11

Bench: Shri. B.R. Baskaran & Smt. Beena Pillaiassessment Year : 2010-11 M/S. Bangalore Metro Rail Corporation Ltd., The Deputy 3Rd Floor, Bmtc Commissioner Of Complex, Income Tax, K H Road, Circle – 1 [1][2], Shanti Nagar, Vs. Bangalore. Bangalore – 560 027. Pan: Aaacb4881D Appellant Respondent Assessee By : Shri Sreehari Kutsa, Advocate : Shri Sumer Singh Meena, Cit Revenue By Dr Date Of Hearing : 25-04-2022 Date Of Pronouncement : 29-04-2022 Order Per Beena Pillaipresent Appeal Has Been Filed By Assessee Against Order Dated 26/02/2019 Passed By The Ld. Cit(A)-1, Bangalore For Assessment Year 2010-11 On Following Grounds Of Appeal: “1. The Order Of The Learned Commissioner Of Income-Tax (Appeals), Passed Under Section 250 Of The Act In So Far As It Is Against The Appellant Is Opposed To Law, Equity, Weight Of Evidence, Probabilities & The Facts & Circumstances In The Appellant'S Case. 2. The Learned Cit(A) Is Not Justified In Refusing To Admit The Appeal Of The Appellant On The Grounds That Delay In Filing Of The Appeal Cannot Be Condoned On The Facts & Circumstances Of The Case.

For Appellant: Shri Sreehari Kutsa, Advocate

Section 234BSection 234DSection 250

with the Hon'ble Chief Commissioner of Income Tax/Director General of Income Tax the Appellant Company denies itself liable to be charged to interest under section 234B and section 234D of the Act which under the facts and circumstances of the case deserves to be cancelled. The Page ... calculation of interest under section 234B and section 234D is not in accordance with law as the rate, amount and method for calculating interest is not discernible from the order of assessment. 10. The Appellant craves leave to add, alter, delete or substitute any of the grounds urged above

Nayan Arvind Lalan, Mumbai vs. ITO, 24(1)(5), Mumbai

In the result, all these five appeals are allowed for statistical purposes

ITA 705/MUM/2019[2013-14]Status: DisposedITAT Mumbai28 Apr 2022AY 2013-14

Bench: Shri Prashant Maharishi, Am & Shri Amarjit Singh, Jm

For Appellant: Mrs. Ruchi M Rathod, ARFor Respondent: Shri C.T. Mathews, DR

Section 131Section 133(6)Section 148Section 68

Para 16 above) TOTAL INCOME 5,04,64,990/- 17. Assessed under section 143(3) r.w.s. 147 of the Income-tax Act, 1961. Interest under section 234B and 234C of the Act is charged as per law. The tax computation sheet ITNS 150 forms part of this order

Nayan Arvind Lalan, Mumbai vs. ITO, 24(1)(5), Mumbai

In the result, all these five appeals are allowed for statistical purposes

ITA 704/MUM/2019[2012-13]Status: DisposedITAT Mumbai28 Apr 2022AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Amarjit Singh, Jm

For Appellant: Mrs. Ruchi M Rathod, ARFor Respondent: Shri C.T. Mathews, DR

Section 131Section 133(6)Section 148Section 68

Nayan Arvind Lalan, Mumbai vs. ITO, 24(1)(5), Mumbai

In the result, all these five appeals are allowed for statistical purposes

ITA 703/MUM/2019[2011-12]Status: DisposedITAT Mumbai28 Apr 2022AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Amarjit Singh, Jm

For Appellant: Mrs. Ruchi M Rathod, ARFor Respondent: Shri C.T. Mathews, DR

Section 131Section 133(6)Section 148Section 68

Nayan Arvind Lalan, Mumbai vs. ITO, 24(1)(5), Mumbai

In the result, all these five appeals are allowed for statistical purposes

ITA 702/MUM/2019[2010-11]Status: DisposedITAT Mumbai28 Apr 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Amarjit Singh, Jm

For Appellant: Mrs. Ruchi M Rathod, ARFor Respondent: Shri C.T. Mathews, DR

Section 131Section 133(6)Section 148Section 68

Nayan Arvind Lalan, Mumbai vs. ITO, 24(1)(5), Mumbai

In the result, all these five appeals are allowed for statistical purposes

ITA 701/MUM/2019[2009-10]Status: DisposedITAT Mumbai28 Apr 2022AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Amarjit Singh, Jm

For Appellant: Mrs. Ruchi M Rathod, ARFor Respondent: Shri C.T. Mathews, DR

Section 131Section 133(6)Section 148Section 68

M/S Irunway India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-3(1)(1), Bangalore

In the result, appeal of the assessee is partly allowed

ITA 229/BANG/2019[2015-16]Status: DisposedITAT Bangalore27 Apr 2022AY 2015-16

Bench: Shri N. V. Vasudevan & Ms. Padmavathy Sassessment Year : 2015-16 M/S. Irunway India Private Limited, Dcit, Vs. Regus Business Center, Office Circle – 3(1)(1), No.1015, Bengaluru. 10Th Floor, Tower-B, Unitech Cyber Park, Sector 39, Gurugram, Gurgaon, Haryana – 122 003. Pan : Aabci 5613 D Appellant Respondent

For Appellant: Shri. T. Suryanarayana, Senior AdvocateFor Respondent: Mrs. Susan D. George, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 195Section 37Section 40

double disallowance of the same amount. With these observations, we dismiss this issue also. 39. The other grounds with regard to levy of interest under section 234B and 234C are purely consequential. The AO is directed to give consequential relief. 40. In the result, appeal of the assessee is partly

M/S Belgacom International Carrier Services Sa, Bangalore vs. Deputy Commissioner of Income Tax Circle-1(1) International Taxation, Bangalore

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

ITA 2884/BANG/2017[2008-09]Status: DisposedITAT Bangalore26 Apr 2022AY 2008-09

Bench: Shri. B.R. Baskaran & Smt. Beena Pillaiit(It)A No. 2884/Bang/2017 Assessment Year : 2008-09 M/S. Belgacom The Deputy International Carrier Commissioner Of Services Sa, Income Tax, Rue Lebeau 4, Circle -1(1), 1000 Brussels, International Taxation, Vs. Belgium. Bangalore. Appellant Respondent : Shri V. Sridharan, Senior Assessee By Advocate : Shri Pradeep Kumar, Cit-Dr & Revenue By Smt. Vandana Sagar, Cit-Dr Date Of Hearing : 16-03-2022 Date Of Pronouncement : 26-04-2022 Order Per Beena Pillaipresent Appeal Is Filed By Non Resident Assessee Against Order Dated 30.10.2017 Passed By Dcit (It), Circle -1(1), Bangalore On Following Grounds Of Appeal: “Being Aggrieved By The Order Of The Learned Dcit, Circle - 1(1), International Taxation, Bengaluru ('A0'), Read With The Order Of The Learned Dispute Resolution Panel ('Drp*), Bengaluru, The Assessee Begs To Prefer The Present Appeal On The Following Grounds: 1. The Learned Ao Erred In Exercising, Jurisdiction U/S 147 Of The Act In The Case Of The Appellant. 2. The Lower Authorities Erred In Holding That A Sum Of Rs. 6,87,13,119/- Received By The Appellant From Its Customer In India Is In The Nature Of 'Royalty' Within The Meaning Of Section 9(1)(Vi) Of The It Act & Accordingly Taxable In India Under The It Act.

For Respondent: Shri V. Sridharan, Senior

Section 143(3)Section 147Section 148Section 234ASection 234BSection 234CSection 9(1)(v)Section 9(1)(vi)Section 9(1)(vii)

Appellant, as the Appellant was not required to file a tax return in India. 9. The lower authorities erred in levying interest under section 234B of the IT Act in the case of the Appellant, as according to the Revenue Authorities, the levy of tax itself has arisen only

Tarkett Flooring India Private Limited, Bengaluru vs. Assistant Commissioner of Income Tax, Circle-7(1)(1), Bangalore

In the result, the appeal is partly allowed

ITA 201/BANG/2021[2016-17]Status: DisposedITAT Bangalore21 Apr 2022AY 2016-17

Bench: Shri N. V. Vasudevan & Ms. Padmavathy Sit(Tp)A No.201/Bang/2021 Assessment Year : 2016-17 M/S. Tarkett Flooring India Pvt. Ltd., Acit, Vs. No.460, 2Nd Cross, Circle – 7(1)(1), Krishna Temple Road, Bengaluru. Binnamangala 1St Stage, Bengaluru-560 038. Pan : Aadct 9947 R Appellant Respondent

For Appellant: Shri. Sumeet Khuranna, CAFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 92Section 92C

facts and in the circumstances of the case, the learned AO erred in not granting consequential relief in the computation of interest under section 234B of the Act while computing the tax payable. 7. At the time of hearing, learned Counsel for the assessee pressed for adjudication of only ground

M/S Jaysons Infrastructure India Private Limited, Bangalore vs. The Income Tax Officer Ward-4(1)(1), Bangalore

In the result, these two assessee’s appeals are treated as partly allowed for statistical purposes

ITA 403/BANG/2019[2012-13]Status: DisposedITAT Bangalore11 Apr 2022AY 2012-13

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Shri Ravi Shankar, Adv

Section 143(3)Section 147Section 148Section 234BSection 80I

erroneous and hence, the order ought to have been set aside as bad in law. 7. 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 ... that “consent does not confer jurisdiction”, on the facts and circumstances of the case. 12. 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

M/S Jaysons Infrastructure India Pvt Ltd, Bangalore vs. The Income Tax Officer Ward-4(1)(1), Bangalore

In the result, these two assessee’s appeals are treated as partly allowed for statistical purposes

ITA 402/BANG/2019[2011-12]Status: DisposedITAT Bangalore11 Apr 2022AY 2011-12

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Shri Ravi Shankar, Adv

Section 143(3)Section 147Section 148Section 234BSection 80I

Strides Pharma Science Ltd, Navi Mumbai vs. Dy CIT 15 (3)(2), Mumbai

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

ITA 7992/MUM/2019[2015-16]Status: DisposedITAT Mumbai06 Apr 2022AY 2015-16

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Nishit Gandhi a/w Ms. Akshita BhandariFor Respondent: Ms. Vatsalaa Jha (CIT)

Section 143(3)Section 144C(1)Section 144C(13)Section 144C(5)Section 92C

no.9, raised in assessee’s appeal is allowed for statistical purpose. 48. Ground no.10, raised in assessee’s appeal relates to levy of interest under section 234B of the Act. Strides Pharma Science Ltd. ITA No.7992/Mum./2019 49. During the course of hearing, the learned A.R. submitted that the ground ... consequential in nature. Thus, the Assessing Officer is directed to compute the interest under section 234B of the Act, if leviable, in accordance with law. Accordingly, ground no.10, raised by the assessee is allowed for statistical purpose. 50. The issue arising in ground no.11, raised in assessee’s appeal

Tata Consultancy Services Ltd, Mumbai vs. Asst CIT Ltu-1, Mumbai

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

ITA 1650/MUM/2016[2011-12]Status: DisposedITAT Mumbai06 Apr 2022AY 2011-12

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Porus Kaka, Sr. AdvocateFor Respondent: Ms. Vatsalaa Jha, CIT–DR

Section 115JSection 143(3)Section 144C(1)Section 144C(13)Section 144C(5)Section 2(43)Section 37Section 40Section 90Section 91

IN THE INCOME TAX APPELLATE TRIBUNAL “J” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH KARHAIL

Sonicwall Technology System India Pvt. Ltd., Mumbai vs. DCIT 10 (3), Mumbai

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

ITA 1807/MUM/2019[2011-12]Status: DisposedITAT Mumbai05 Apr 2022AY 2011-12

Bench: Shri Pramod Kumar () & Ms. Suchitra Kamble () Sonicwall Technology System Dy. Commissioner Of India Private Limited, Vs. Income-Tax-10(3) (Formerly Known As Dell Software India Room No. 451, Aayakar Pvt. Ltd.) (Formerly Known As Qsft Bhavan, New Marine Lines, India Pvt. Ld.) Mumbai – 400 020 Plot No. C-70, G-Block Bandra Kurla Complex Bandra (East) Mumbai – 400 051 Pan No. Aaacq1441N (Assessee) (Revenue)

For Appellant: Shri Manasa Ananthan, A.RFor Respondent: Shri Hoshang B. Irani, D.R

Section 143(1)Section 143(2)Section 234BSection 271(1)(c)

service tax and foreign exchange fluctuation from the expenses while applying the mark up on cost. 7. That the AO erred in levying interest under section 234B and 234DoftheAct. 8. That the AO erred in initiating penalty proceedings under section 271(1)(c) of the Act. 9. That the impugned

M/S. United Spirits Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-7(1)(1), Bengaluru

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

ITA 2701/BANG/2017[2013-14]Status: DisposedITAT Bangalore04 Apr 2022AY 2013-14

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.2701/Bang/2017 : Asst.Year 2013-2014 M/S.United Spirits Limited The Deputy Commissioner Of Ub Towers, Income-Tax, Circle 7(1)(1) V. No.24 Vittal Mallya Road Bangalore. Bangalore – 560 001. Pan : Aaccm8043J. (Appellant) (Respondent) Appellant By : Sri.Percy Pardiwala, Senior Advocate Respondent By : Sri.Pradeep Kumar, Cit-Dr Date Of Pronouncement : 05.04.2022 Date Of Hearing : 24.03.2022 O R D E R Per George George K, Jm : This Appeal At The Instance Of The Assessee Is Directed Against Final Assessment Order Dated 12.10.2017 Passed U/S 143(3) R.W.S. 144C(13) Of The I.T.Act. The Relevant Assessment Year Is 2013-2014. 2. The Brief Facts Of The Case Are As Follows: The Assessee Is A Company Engaged In The Manufacture & Sale Of Alcoholic Beverage. The Assessee Filed Its Return Of Income For The Assessment Year 2013-2014 On 28.11.2013 Which Was Selected For Scrutiny Assessment. During The Course Of Assessment, The Assessee’S Case Was Also Referred To The Transfer Pricing Officer (Tpo). The Tpo Vide Order Dated 26.10.2016, Recommended Transfer Pricing Adjustments. The A.O., Thereafter, Passed A Draft Assessment Order Dated 30.12.2016. 2 It(Tp)A No.2701/Bang/2017 M/S.United Spirits Limited.

For Appellant: Sri.Percy Pardiwala, Senior AdvocateFor Respondent: Sri.Pradeep Kumar, CIT-DR

Section 143(3)Section 14ASection 234BSection 234CSection 36(1)(iii)

State Bank of India's PLR rate of 14.5% 12 IT(TP)A No.2701/Bang/2017 M/s.United Spirits Limited. without any basis. 9. Levy of interest under section 234B of the Act - Rs. 181,25,18,840 9.1. The learned AO has erred in computing interest under section 234B which is consequential

M/S Metrik Infraprojects Private Limited, Bangalore vs. Assistant Commissioner of Income Tax Circle-4(1)(2), Bangalore

In the result appeal filed by assessee stands allowed for statistical purposes

ITA 52/BANG/2019[2012-13]Status: DisposedITAT Bangalore31 Mar 2022AY 2012-13

For Respondent: Shri S.V. Ravishankar

Section 234BSection 234D

passed ought to have been set aside, on the facts and circumstances of the case. 8. The appellant denies the liability to pay interest under section 234B and section 234D of the Act in view of the fact that there is no liability to additional tax as determined

Tata Power Solar Systems Limited, Bangalore vs. DCIT, Bangalore

In the result, the appeal filed by the assessee stands allowed on the legal issue

ITA 699/BANG/2016[2011-12]Status: DisposedITAT Bangalore30 Mar 2022AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 548/Bang/2016 Assessment Year : 2011-12 M/S. Tata Power Solar The Deputy Systems Ltd., Commissioner Of 78, Electronic City, Income Tax, Hosur Road, Circle – 7(1)(1), Bangalore – 560 100. Bangalore. Vs. Pan: Aaact4660J Appellant Respondent & It(Tp)A No. 699/Bang/2016 Assessment Year : 2011-12 (By Assessee) Assessee By : Shri Kanchun Kaushal, Ca : Shri Manjunath Karkihalli, Revenue By Cit-Dr Date Of Hearing : 14-02-2022 Date Of Pronouncement : 30-03-2022 Order Per Beena Pillaipresent Cross Appeals By Assessee & Revenue Arises Out Of Final Assessment Order Dated 28.01.2016 Passed By The Ld.Dcit, Circle -7 (1)(1), Bangalore For Assessment Year 2011-12 On Following Grounds Of Appeal: It(Tp)A No. 548/Bang/2016 (Revenue’S Appeal): “1. The Directions Of The Dispute Resolution Panel Are Opposed To Law & Facts Of The Case.

For Appellant: Shri Kanchun Kaushal, CA

Section 144C

699/Bang/2016 115P of the Act at INR ...... 39,60,390. [corresponding to Ground 8] 15. The learned AO erred in charging interest under section 234B and 234C of the Act. [corresponding to Ground 9] That the Appellant craves leave to add to and/or to alter, amend, rescind, modify the grounds

DCIT, Bangalore vs. M/S Tata Power Solar Systems Ltd., Bangalore

In the result, the appeal filed by the assessee stands allowed on the legal issue

ITA 548/BANG/2016[2011-12]Status: DisposedITAT Bangalore30 Mar 2022AY 2011-12

For Appellant: Shri Kanchun Kaushal, CA

Section 144C

M/S. Satyam Realtors P. Ltd., Mumbai vs. Dy CIT CC-5(4)Dy CIT CC-5(4), Mumbai

In the result, appeal by the assessee stands partly allowed

ITA 552/MUM/2021[2013-14]Status: DisposedITAT Mumbai25 Mar 2022AY 2013-14

Bench: Shri Shamim Yahya

Section 147Section 148Section 234B

closing stock. 2 3) The 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. 4) The Appellant craves leave to add to and/ or amend and/ or delete and/ or modify