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“interest under section 234C”

InterestSection 234CSection 234C353 judgments

The decision most relied on for interest under section 234C is CIT v. Anjum M.H. Ghaswala (252 ITR 1), cited in 452 judgments on BharatTax.

Leading authorities on interest under section 234C

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.

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.

CIT v. Tata Autocomp Systems Ltd.
56 Taxmann.com 206 · 2015 · High Court
119
citing judgments

When determining the arm's length price for interest on a foreign currency loan advanced to an Associated Enterprise, the Indian Prime Lending Rate is not applicable. Instead, the interest rate should be benchmarked based on the prevailing foreign currency rate, such as EURIBOR, or the rate in the country where the loan is received/consumed.

CIT v. Pfizer Ltd.
330 ITR 62 · 2011 · High Court
78
citing judgments

An insurance claim received on stock in trade constitutes business income and is not an independent source of income.

Pr. CIT v. Ankit Metal & Power Ltd.
109 Taxmann.com 93 · 2019 · High Court
77
citing judgments

Capital receipts, such as interest and power subsidy, are not includible in book profit under Section 115JB as they do not fall within the definition of income under Section 2(24).

Judgments citing interest under section 234C

Piramal Enterprises Limited, Mumbai vs. DCIT, CPC, Bangalore

In the result, the appeal by the assessee is allowed

ITA 1293/MUM/2023[2017-2018]Status: DisposedITAT Mumbai19 Jul 2023AY 2017-2018

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Ronak Doshi a/wFor Respondent: Shri Ashok Kumar Ambartha
Section 115JSection 143(1)Section 154Section 234CSection 234C(1)Section 250

grounds of appeal on or before the date of hearing.” 3. The only dispute raised by the assessee is against the levy of interest under section 234C of the Act. 4. The brief facts of the case pertaining to this issue, as emanating from the record, are that the assessee ... adjustment to income made under section 143(1) of the Act and the only grievance of the assessee is regarding erroneous levy of interest under section 234C of the Act. The learned CIT(A) further held that an effective remedy in this regard is under section

Ameriprise India Pvt. Ltd., New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is allowed

ITA 1198/DEL/2016[2011-12]Status: DisposedITAT Delhi17 Jul 2023AY 2011-12

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Sh. Kamal Sawhney Adv. &For Respondent: Sh. P. Praveen Sidharth, CIT DR
Section 143(3)Section 234CSection 271(1)(c)Section 37(1)

aforesaid ground shall not be pressed where the application is allowed by the learned AO, 4. Ground No. 4-Levy of interest under section 234C of the Act 3 Ameriprise India Pvt. Ltd. 4.1 On the facts and circumstances of the case and in law, the learned AO has erred ... charging interest under section 234C of the Act. The Appellant has filed a rectification application before the learned AO for rectification of the above mistake and the aforesaid ground shall not be pressed where the application is allowed by the learned AO 5. Ground No. 5- Initiation of penalty proceedings

Dy. Comm of Income Tax-Central Circle 6(3), Mumbai vs. Beil Infrastructure, Gujarat

In the result, appeal of the Revenue is partly allowed for statistical purpose

ITA 1950/MUM/2022[2015-16]Status: DisposedITAT Mumbai30 Jun 2023AY 2015-16

Bench: Shri Vikas Awasthy & Shri Om Prakash Kantvk-Vk-La- 586@Eaqcbz@2017 ¼Fu-Oa- 2012&13½ Beil Infrastructure Limited (Earlier Known As Bharuch Enviro Infrastructure Limited) Plot No.9701-16, Gidc Estate, Ankleshwar Gujarat-393 002 ..... Vihykfkhz/Appellant Pan No. Aaacb8075F Cuke Vs. Deputy Commissioner Of Income Tax, Cc-6(3) Room No. 1903, 19Th Floor, Air India Building, Nariman Point ..... Izfroknh/Respondent Mumbai-400 021 Vk-Vk-La- 400@Eaqcbz@2017 ¼Fu-Oa- 2012&13½ Vk-Vk-La- 1950@Eaqcbz@2022 ¼Fu-Oa- 2015&16½ Deputy Commissioner Of Income Tax, Cc-6(3) Room No. 1903, 19Th Floor, Air India Building, Nariman Point ..... Vihykfkhz/Appellant Mumbai-400 021 Cuke Vs. Beil Infrastructure Limited (Earlier Known As Bharuch Enviro Infrastructure Limited) Plot No.117/18, Gidc Estate, Ankleshwar Gujarat-393 002 ..... Izfroknh/Respondent Pan No. Aaacb8075F

For Appellant: Shri Kirit Kamdar &For Respondent: Shri Salil Mishra, CIT-DR
Section 115JSection 14ASection 234CSection 80Section 801A

facts and in circumstances of the case and in law, the CIT(A) erred in upholding the action of the AO in levying interest under section 234C of the Act without appreciating the fact that amount under section 234C ought to be levied as per the return of income

Beil Infrastructure Limited ('Beil')(Earlier Known As Bharuch Enviro Infrastructure Ltd), Gujrat vs. DCIT Cen Cir 6(3), Mumbai

In the result, appeal of the Revenue is partly allowed for statistical purpose

ITA 586/MUM/2017[2012-13]Status: DisposedITAT Mumbai30 Jun 2023AY 2012-13

Bench: Shri Vikas Awasthy & Shri Om Prakash Kantvk-Vk-La- 586@Eaqcbz@2017 ¼Fu-Oa- 2012&13½ Beil Infrastructure Limited (Earlier Known As Bharuch Enviro Infrastructure Limited) Plot No.9701-16, Gidc Estate, Ankleshwar Gujarat-393 002 ..... Vihykfkhz/Appellant Pan No. Aaacb8075F Cuke Vs. Deputy Commissioner Of Income Tax, Cc-6(3) Room No. 1903, 19Th Floor, Air India Building, Nariman Point ..... Izfroknh/Respondent Mumbai-400 021 Vk-Vk-La- 400@Eaqcbz@2017 ¼Fu-Oa- 2012&13½ Vk-Vk-La- 1950@Eaqcbz@2022 ¼Fu-Oa- 2015&16½ Deputy Commissioner Of Income Tax, Cc-6(3) Room No. 1903, 19Th Floor, Air India Building, Nariman Point ..... Vihykfkhz/Appellant Mumbai-400 021 Cuke Vs. Beil Infrastructure Limited (Earlier Known As Bharuch Enviro Infrastructure Limited) Plot No.117/18, Gidc Estate, Ankleshwar Gujarat-393 002 ..... Izfroknh/Respondent Pan No. Aaacb8075F

For Appellant: Shri Kirit Kamdar &For Respondent: Shri Salil Mishra, CIT-DR
Section 115JSection 14ASection 234CSection 80Section 801A

facts and in circumstances of the case and in law, the CIT(A) erred in upholding the action of the AO in levying interest under section 234C of the Act without appreciating the fact that amount under section 234C ought to be levied as per the return of income

DCIT CC 6(3), Mumbai vs. M/S Beil Infrastructure Ltd. ( Earlier Known As Bharuch Enviro Infrastructure Ltd, Anlkleshwar

In the result, appeal of the Revenue is partly allowed for statistical purpose

ITA 400/MUM/2017[2012-13]Status: DisposedITAT Mumbai30 Jun 2023AY 2012-13

Bench: Shri Vikas Awasthy & Shri Om Prakash Kantvk-Vk-La- 586@Eaqcbz@2017 ¼Fu-Oa- 2012&13½ Beil Infrastructure Limited (Earlier Known As Bharuch Enviro Infrastructure Limited) Plot No.9701-16, Gidc Estate, Ankleshwar Gujarat-393 002 ..... Vihykfkhz/Appellant Pan No. Aaacb8075F Cuke Vs. Deputy Commissioner Of Income Tax, Cc-6(3) Room No. 1903, 19Th Floor, Air India Building, Nariman Point ..... Izfroknh/Respondent Mumbai-400 021 Vk-Vk-La- 400@Eaqcbz@2017 ¼Fu-Oa- 2012&13½ Vk-Vk-La- 1950@Eaqcbz@2022 ¼Fu-Oa- 2015&16½ Deputy Commissioner Of Income Tax, Cc-6(3) Room No. 1903, 19Th Floor, Air India Building, Nariman Point ..... Vihykfkhz/Appellant Mumbai-400 021 Cuke Vs. Beil Infrastructure Limited (Earlier Known As Bharuch Enviro Infrastructure Limited) Plot No.117/18, Gidc Estate, Ankleshwar Gujarat-393 002 ..... Izfroknh/Respondent Pan No. Aaacb8075F

For Appellant: Shri Kirit Kamdar &For Respondent: Shri Salil Mishra, CIT-DR
Section 115JSection 14ASection 234CSection 80Section 801A

facts and in circumstances of the case and in law, the CIT(A) erred in upholding the action of the AO in levying interest under section 234C of the Act without appreciating the fact that amount under section 234C ought to be levied as per the return of income

Strides Shasun Ltd, Navi Mumbai vs. DCIT Cir 15(3)(2), Mumbai

ITA 1992/MUM/2016[2011-12]Status: DisposedITAT Mumbai28 Jun 2023AY 2011-12

Bench: Shri Kuldip Singh & Ms. Padmavathy Sassessment Year: 2011-12

For Appellant: Shri Ninad Patade, A.RFor Respondent: Shri Manoj Kumar, CIT D.R
Section 143Section 144C(1)Section 14ASection 92C

dismissed having been become infructuous. Ground No.10 23. Ground No.10 is consequential in nature, hence needs no finding. Ground No.11 24. No interest under section 234C is liable to be levied when there is no shortfall in the payment of tax by the assessee. The Ld. A.R. for the assessee

J.B.Chemicals & Pharmaceuticals Ltd., Mumbai vs. DCIT -CC -2(1), Mumbai

The appeals of the assessee are partly allowed

ITA 2009/MUM/2019[2013-14]Status: DisposedITAT Mumbai27 Jun 2023AY 2013-14

Bench: Shri Aby T. Varkey () & Ms. Padmavathy S. ()

Section 234ASection 234CSection 35

with law. Needless to say that the assessee be given a reasonable opportunity of being heard. It is ordered accordingly. Incorrect consideration of interest under section 234C 29. In this regard, it is submitted that the Assessing Officer has erroneously computed the interest under section 234C whereas there ... income returned by the assessee. The Ld.AR further 31 2008 & 2009/Mum/2019 ITA 4656 & 4657/M/2018 J.B. Chemicals & Pharmaceuticals Ltd submitted that the interest under section 234C is charged for the shortfall in the payments of advance-tax on the income returned and not income assessed. Therefore, the Ld.AR prayed

J.B.Chemicals & Pharmaceuticals Ltd., Mumbai vs. DCIT -CC -2(1), Mumbai

The appeals of the assessee are partly allowed

ITA 2008/MUM/2019[2012-13]Status: DisposedITAT Mumbai27 Jun 2023AY 2012-13

Bench: Shri Aby T. Varkey () & Ms. Padmavathy S. ()

Section 234ASection 234CSection 35

with law. Needless to say that the assessee be given a reasonable opportunity of being heard. It is ordered accordingly. Incorrect consideration of interest under section 234C 29. In this regard, it is submitted that the Assessing Officer has erroneously computed the interest under section 234C whereas there ... income returned by the assessee. The Ld.AR further 31 2008 & 2009/Mum/2019 ITA 4656 & 4657/M/2018 J.B. Chemicals & Pharmaceuticals Ltd submitted that the interest under section 234C is charged for the shortfall in the payments of advance-tax on the income returned and not income assessed. Therefore, the Ld.AR prayed

J.B. Chemicals and Pharmaceutical Ltd, Mumbai vs. DCIT Cen Cir 2(1), Mumbai

The appeals of the assessee are partly allowed

ITA 4657/MUM/2018[2015-16]Status: DisposedITAT Mumbai27 Jun 2023AY 2015-16

Bench: Shri Aby T. Varkey () & Ms. Padmavathy S. ()

Section 234ASection 234CSection 35

with law. Needless to say that the assessee be given a reasonable opportunity of being heard. It is ordered accordingly. Incorrect consideration of interest under section 234C 29. In this regard, it is submitted that the Assessing Officer has erroneously computed the interest under section 234C whereas there ... income returned by the assessee. The Ld.AR further 31 2008 & 2009/Mum/2019 ITA 4656 & 4657/M/2018 J.B. Chemicals & Pharmaceuticals Ltd submitted that the interest under section 234C is charged for the shortfall in the payments of advance-tax on the income returned and not income assessed. Therefore, the Ld.AR prayed

J.B. Chemicals and Pharmaceutical Ltd, Mumbai vs. DCIT Cen Cir 2(1), Mumbai

The appeals of the assessee are partly allowed

ITA 4656/MUM/2018[2014-15]Status: DisposedITAT Mumbai27 Jun 2023AY 2014-15

Bench: Shri Aby T. Varkey () & Ms. Padmavathy S. ()

Section 234ASection 234CSection 35

with law. Needless to say that the assessee be given a reasonable opportunity of being heard. It is ordered accordingly. Incorrect consideration of interest under section 234C 29. In this regard, it is submitted that the Assessing Officer has erroneously computed the interest under section 234C whereas there ... income returned by the assessee. The Ld.AR further 31 2008 & 2009/Mum/2019 ITA 4656 & 4657/M/2018 J.B. Chemicals & Pharmaceuticals Ltd submitted that the interest under section 234C is charged for the shortfall in the payments of advance-tax on the income returned and not income assessed. Therefore, the Ld.AR prayed

Strides Arcolab Ltd, Navi Mumbai vs. DCIT Cir 15(3)(2), Mumbai

The appeal of the assessee is allowed

ITA 1903/MUM/2015[2010-11]Status: DisposedITAT Mumbai23 May 2023AY 2010-11

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

Section 10BSection 115JSection 143(3)Section 144CSection 14ASection 35Section 92C

1 ITA 1903/Mum/2015 M/s Strides Arcolab Limited IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “J”, MUMBAI BEFORE AMIT SHUKLA

Thr Infrastructure Pte Ltd, Gurgaon vs. DCIT, Cir.-3(1)(1), Intl Tax, New Delhi

In the result, the appeal of the assessee is allowed

ITA 1915/DEL/2022[201-18]Status: DisposedITAT Delhi12 May 2023

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. Gangadhar Panda, CIT-DR
Section 143(3)

read with tax rate scheduled in the Finance Act which provides tax rate @ 20%. 9. The Ld. AO has erred in computing interest under section 234C of the Act on the tax demand, without appreciating that the same is applicable on the returned income and not on the assessed income

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

NFAC erred in levying additional interest under the NFAC erred in levying additional interest under the NFAC erred in levying additional interest under Section 234C of the Act. Section 234C of the Act. The Appellant prays that the additional interest levied The Appellant prays that the additional interest levied

Bharuch Enviro Infrastructure Ltd., Ankleshwar vs. Addl.CIT, Bharuch Circle, Bharuch

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

ITA 504/AHD/2015[2011-12]Status: DisposedITAT Surat24 Apr 2023AY 2011-12

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 143(3)Section 147Section 148Section 234BSection 234B(3)Section 254(1)Section 80Section 80I

facts and in circumstances of the case and in law, the CIT(A) erred in upholding the action of the AO in levying interest under section 234C of the Act without appreciating the fact that amount under section 234C ought to be levied as per the return of income ... circumstances of the case and in law, the CIT(A) erred in upholding the action of the AO in levying interest under Section 234C of the Act without appreciating the fact that amount under Section 234C ought to be levied as per the return of income. The appellant hereby reserves

Bharuch Enviro Infrastructure Ltd., Ankleshwar vs. ACIT, Bharuch Circle, Bharuch

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

ITA 503/AHD/2015[2010-11]Status: DisposedITAT Surat24 Apr 2023AY 2010-11

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 143(3)Section 147Section 148Section 234BSection 234B(3)Section 254(1)Section 80Section 80I

facts and in circumstances of the case and in law, the CIT(A) erred in upholding the action of the AO in levying interest under section 234C of the Act without appreciating the fact that amount under section 234C ought to be levied as per the return of income ... circumstances of the case and in law, the CIT(A) erred in upholding the action of the AO in levying interest under Section 234C of the Act without appreciating the fact that amount under Section 234C ought to be levied as per the return of income. The appellant hereby reserves

Bharuch Enviro Infrastructure Ltd., Ankleshwar vs. Dy. Commissioner of Income Tax, Bharuch Circle, Bharuch

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

ITA 502/AHD/2015[2009-10]Status: DisposedITAT Surat24 Apr 2023AY 2009-10

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 143(3)Section 147Section 148Section 234BSection 234B(3)Section 254(1)Section 80Section 80I

facts and in circumstances of the case and in law, the CIT(A) erred in upholding the action of the AO in levying interest under section 234C of the Act without appreciating the fact that amount under section 234C ought to be levied as per the return of income ... circumstances of the case and in law, the CIT(A) erred in upholding the action of the AO in levying interest under Section 234C of the Act without appreciating the fact that amount under Section 234C ought to be levied as per the return of income. The appellant hereby reserves

Bharuch Enviro Infrastructure Ltd., Ankleshwar vs. Dy. Commissioner of Income Tax, Bharuch Circle, Bharuch

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

ITA 501/AHD/2015[2008-09]Status: DisposedITAT Surat24 Apr 2023AY 2008-09

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 143(3)Section 147Section 148Section 234BSection 234B(3)Section 254(1)Section 80Section 80I

facts and in circumstances of the case and in law, the CIT(A) erred in upholding the action of the AO in levying interest under section 234C of the Act without appreciating the fact that amount under section 234C ought to be levied as per the return of income ... circumstances of the case and in law, the CIT(A) erred in upholding the action of the AO in levying interest under Section 234C of the Act without appreciating the fact that amount under Section 234C ought to be levied as per the return of income. The appellant hereby reserves

Bharuch Enviro Infrastructure Ltd., Ankleshwar vs. Dy. Commissioner of Income Tax, Bharuch

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

ITA 500/AHD/2015[2007-08]Status: DisposedITAT Surat24 Apr 2023AY 2007-08

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 143(3)Section 147Section 148Section 234BSection 234B(3)Section 254(1)Section 80Section 80I

facts and in circumstances of the case and in law, the CIT(A) erred in upholding the action of the AO in levying interest under section 234C of the Act without appreciating the fact that amount under section 234C ought to be levied as per the return of income ... circumstances of the case and in law, the CIT(A) erred in upholding the action of the AO in levying interest under Section 234C of the Act without appreciating the fact that amount under Section 234C ought to be levied as per the return of income. The appellant hereby reserves

Bharuch Enviro Infrastructure Limited, Ankleshwar vs. The Dy.CIT, Bharuch Circle, Bharuch

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

ITA 1935/AHD/2015[2009-10]Status: DisposedITAT Surat24 Apr 2023AY 2009-10

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 143(3)Section 147Section 148Section 234BSection 234B(3)Section 254(1)Section 80Section 80I

facts and in circumstances of the case and in law, the CIT(A) erred in upholding the action of the AO in levying interest under section 234C of the Act without appreciating the fact that amount under section 234C ought to be levied as per the return of income ... circumstances of the case and in law, the CIT(A) erred in upholding the action of the AO in levying interest under Section 234C of the Act without appreciating the fact that amount under Section 234C ought to be levied as per the return of income. The appellant hereby reserves

Gujarat Narmada Valley Fertilizers and Chemicals Ltd., Bharuch vs. Deputy Commissiner of Income Tax, Circle 2(1)(1), Vadodara

In the result, ground no.3 raised by the assessee is allowed for statistical purposes

ITA 13/SRT/2023[2008-09]Status: DisposedITAT Surat18 Apr 2023AY 2008-09

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.13/Srt/2023 "नधा"रण वष"/Assessment Year: (2008-09) (Virtual Hearing) Gujarat Narmada Valley Deputy Commissioner If Income- Fertilizers & Chemicals Limited, Tax, Circle -2(1)(1), Room No. 403, 4Th Floor, Aaykar Bhavan, P.O. Narmadanagar, Bharuch- – Vs. 392015. Race Course Circle, Vadodara- 390 007 (""थ" /Respondent) (अपीलाथ" /Appellant) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaacg8372Q िनधा"रती की ओर से /Appellant By Shri Yogesh Shah, Ar राज"व क" ओर से /Respondent By Shri Vinod Kumar, Sr. Dr सुनवाई की तारीख/Date Of Hearing 11/04/2023 घोषणा की तारीख/Date Of Pronouncement 18/04/2023

Section 143(3)Section 234CSection 234D

no.3 raised by the assessee is allowed for statistical purposes. 15. Ground No.4 and 5 raised by the assessee relates to charging of interest under section 234C and 234D of the Income Tax Act. 16. We note that these grounds are consequential in nature, therefore we direct the Assessing Officer ... compute the interest under section 234C and 234D in accordance with the provisions of law. Therefore, ground nos.4 and 5 raised by the assessee are allowed for statistical purposes. 17. In the result, appeal filed by the assessee is partly allowed for statistical purposes in above terms. Order pronounced