“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

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

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

Astrazeneca Pharma India Limited, Bangalore vs. Deputy Commissioner of Income Tax, Ltu, Circle-1, Bangalore

In the result, the revenue appeal is dismissed and the appeal filed by the assessee is partly allowed

ITA 460/BANG/2016[2011-12]Status: DisposedITAT Bangalore30 Nov 2022AY 2011-12

Bench: Smt. Beena Pillai & Ms. Padmavathy S.It(Tp)A No. 460/Bang/2016 (Assessment Year: 2011-12)

For Appellant: Shri Nageswar Rao, AdvFor Respondent: Shri Manjunath Karkihalli, CIT-DR

Section 143(2)Section 143(3)Section 144CSection 144C(11)

India on behalf of its AE. General Grounds 21 The learned AO has erred in law and on facts, in levying interest under section 234C of the Act on income declared in the original return of income as against the income declared in the revised return of income resulting

DCIT, Bangalore vs. M/S Astra Zenca Pharma India Ltd., Bangalore

In the result, the revenue appeal is dismissed and the appeal filed by the assessee is partly allowed

ITA 446/BANG/2016[2011-12]Status: DisposedITAT Bangalore30 Nov 2022AY 2011-12

Bench: Smt. Beena Pillai & Ms. Padmavathy S.It(Tp)A No. 460/Bang/2016 (Assessment Year: 2011-12)

For Appellant: Shri Nageswar Rao, AdvFor Respondent: Shri Manjunath Karkihalli, CIT-DR

Section 143(2)Section 143(3)Section 144CSection 144C(11)

Sr Technics Switzerland Limited, Mumbai vs. ACIT (It)-4(2)(2), Mumbai

ITA 6616/MUM/2018[2015-16]Status: DisposedITAT Mumbai25 Nov 2022AY 2015-16

Bench: Shri Vikas Awasthy & Shri Gagan Goyals.R. Technics Switzerland Limited. C/O. B-206, Citipoint, A.K. Road, Andheri (East), Mumbai-400059. Pan: Aalcs3475M ...... Appellant Vs. Acit (International Taxation), Range- 4(2) (2), Mumbai-400020. ..... Respondent Appellant By : Sh. Dhanesh Bafna / Sh. Pratik Shah Respondent By : Ms. Surabhi Sharma, Cit-Dr Date Of Hearing : 29/08/2022 Date Of Pronouncement : 25/11/2022 Order Per Gagan Goyal, A.M: This Appeal By The Assessee Is Directed Against The Order Of Acit(It-4(2)(2), Mumbai, [Hereinafter Referred To As [‘Acit’] Dated 24.09.2018 Passed Under Section 143(3) Read With Section 144(C)(13) Of The Income Tax Act, 1961 (Hereinafter Referred To As [‘The Act’] For The Assessment Year (Ay) 2015-16. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Sh. Dhanesh Bafna / Sh. Pratik ShahFor Respondent: Ms. Surabhi Sharma, CIT-DR

Section 143(3)Section 144Section 234BSection 234CSection 234DSection 245Section 271(1)(c)Section 9(1)

facts and circumstances of the case and Rs. 23,068/- in law, the Ld. AO erred in computing interest under Section 234C of the IT Act of Rs. 4, 78,770 instead of Rs. 4, 55,702 as computed on returned income. 9. On the facts and circumstances

DCIT, Corporate Cirlce - 3 (2), Chennai vs. M/S. Venture Lighting India Ltd., Chennai

In the result, the appeal filed by the Revenue is dismissed

ITA 704/CHNY/2020[2008-09]Status: DisposedITAT Chennai18 Nov 2022AY 2008-09

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.704/Chny/2020 िनधा"रण वष"/Assessment Year: 2008-09 The Deputy Commissioner Of Vs. M/S. Venture Lighting India Ltd., Income Tax, Plot No. A-30, D-5, Phase Ii, Corporate Circle – 3(2), Zone-B, Mepz, Tambaram, Chennai – 600 034. Chennai 600 045. [Pan: Aaaca9284H] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri P. Sajit Kumar, Jcit ""थ" की ओर से/Respondent By : Shri S. Sridhar, Advocate सुनवाई की तारीख/ Date Of Hearing : 19.10.2022 घोषणा की तारीख /Date Of Pronouncement : 18.11.2022 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Revenue Is Directed Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-7, Chennai, Dated 09.03.2020 For The Assessment Year 2008-09. 2. The Appeal Filed By The Revenue Is Delayed By 78 Days In Filing The Appeal Due To Outbreak Of Covid-19 Pandemic & Hence, The Delay In Filing The Appeal Is Condoned & Admitted The Appeal For 2

For Appellant: Shri P. Sajit Kumar, JCITFor Respondent: Shri S. Sridhar, Advocate

Section 143(2)Section 143(3)Section 147Section 148Section 234C

debt in the balance sheet and the same has not been added while computing the total income and there is short levy of interest under section 234C of the Act in the said order dated 09.12.2011. In addition to the above, the assessee company has not added the foreign exchange ... debt in the balance sheet and the same has not been added while computing the total income and there is short levy of interest under section 234C of the Act in the said order dated 09.12.2011. In addition to the above, the assessee company has not added the foreign exchange

Joint Commissioner of Income Tax (Ltu), Bangalore vs. M/S Dell International Services India Pvt Ltd, Bangalore

In the result, the appeal of the assessee is partly allowed and the revenue’s appeal is allowed for statistical purposes

ITA 134/BANG/2018[2012-13]Status: DisposedITAT Bangalore11 Nov 2022AY 2012-13

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Shri Praveen Karanth, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 250Section 92CSection 92C(3)

consequential. Ground no.5 is with regard to levy of interest u/s. 234C where it is submitted that the lower authorities erred in levying interest under Section 234C without appreciating that the same is applicable on returned income and not on assessed income are consequential in nature. We therefore direct

M/S Dell International Services India Pvt Ltd, Bangalore vs. Joint Commisssioner of Income Tax Ltu, Bangalore

In the result, the appeal of the assessee is partly allowed and the revenue’s appeal is allowed for statistical purposes

ITA 2834/BANG/2017[2012-13]Status: DisposedITAT Bangalore11 Nov 2022AY 2012-13

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Shri Praveen Karanth, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 250Section 92CSection 92C(3)

Ness Digital Engineering (India) Private Limited, Mumbai vs. The Addl/Jt/Dy/Asstt/CIT/NFAC Delahi, Delhi

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

ITA 825/MUM/2022[2017-18]Status: DisposedITAT Mumbai07 Nov 2022AY 2017-18

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Shashank MehtaFor Respondent: Shri Samuel Pitta

Section 143Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 234Section 234CSection 270ASection 274Section 92C

view of our aforesaid findings and therefore, same need no separate adjudication. 10. Grounds No. 10 and 11 pertain to levy of interest under section 234C of the Act, which is consequential in nature. Therefore, the said grounds are allowed for statistical purpose. 11. Ground no. 12 is pertaining

Mahindra & Mahindra Ltd, Mumbai vs. ACIT RG 2(2)(2), Mumbai

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

ITA 7287/MUM/2018[2014-15]Status: DisposedITAT Mumbai07 Nov 2022AY 2014-15

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri H.P. MahajaniFor Respondent: Smt. Mahita Nair

Section 143(3)Section 144C(13)Section 144C(5)Section 14ASection 92C

Therefore, the Company is not liable to pay any interest us 234A of the Act and the same merits deletion. 23. Interest under Section 234C: The ACIT erred in levying the interest of Rs 8,98,38,802 under section 234C without considering the fact that there was no deferment

Prajosh Nanu, Mumbai-400022 vs. Asst. Dirctor of Income Tax, CPC, Bangalore

In the result, the appeal of the assessee is allowed

ITA 1169/MUM/2022[2019-20]Status: DisposedITAT Mumbai21 Oct 2022AY 2019-20

Bench: Shri B. R. Baskaran, Am & Shri Aby T. Varkey, Jm आयकर अपील सं/ I.T.A. No.1169/Mum/2022 (निर्धारण वर्ा / Assessment Years: 2019-20) Prajosh Nanu बिधम/ Acit, Cpc Room No. 3, Plot No. 265, Vs. Sanjoli Building, Sulochana Shetti, Marg Sion West, Mumbai-400022. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Apkpk0260R (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Ajit Jain & Siddhesh Chaugule Revenue By: Shri P. D. Chougule (Sr. Ar) सुनवाई की तारीख / Date Of Hearing: 06/10/2022 घोषणा की तारीख /Date Of Pronouncement: 21/10/2022 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) (Nfac), Delhi Dated 22.03.2022 For The Assessment Year 2019-20. 2. The Relevant Grounds Of Appeal Raised By The Assessee Are As Under: - “1. In The Facts & Circumstances Of The Case & In Law, The Learned Commissioner Of Income Tax (Appeals) Herein Referred As ‘The Ld. Cit (A)’ Has Erred In Not Granting The Credit Of Foreign Taxes Paid As Should Have Been Duly Allowed Under Article 24(2) Of The India-Uk Double Tax Avoidance Agreement (‘Dtaa’) Read With Section 90 Of The Act, Even Though The Appellant Was ‘Resident’ In India & Therefore, Had Offered His Global Income To Tax In India Including The Uk Sourced Income Which Had Suffered Tax In Uk As Well.

For Appellant: Shri Ajit Jain & SiddheshFor Respondent: Shri P. D. Chougule (Sr. AR)

Section 143(1)Section 154Section 234CSection 90

erred in upholding the action of the Ld. Assistant Director of Income Tax, CPC in levying additional interest under section 234C of the Act.” 3. The main grievance of the assessee is against the action of the Ld. CIT(A) in confirming the action of the AO by not granting

Medreich Limited, Bangalore vs. Assistant Commissioner of Income Tax, Central Circle-1(2), Bangalore

In the result, the appeal filed by the assessee stands allowed as indicated hereinabove

ITA 451/BANG/2022[2017-18]Status: DisposedITAT Bangalore21 Oct 2022AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 451/Bang/2022 Assessment Year : 2017-18 M/S. Medreich Ltd., No. 12/8, Medreich The Assistant House, Commissioner Of Saraswati Ammal Income Tax, Street, Central Circle – Maruti Seva Nagar, 1(2), Vs. Bangalore – 560 033. Bangalore. Pan: Aabcm1458Q Appellant Respondent : Shri Padam Chand Assessee By Khincha, Ca : Shri Praveen Karanth, Revenue By Cit-Dr Date Of Hearing : 27-07-2022 Date Of Pronouncement : 21-10-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Passed By The Ld.Acit, Central Circle – 1(2), Bangalore Dated 26/04/2022 For A.Y. 2017-18 On Following Grounds Of Appeal: “General Ground 1.1 The Learned Assistant Commissioner Of Income Tax, Central Circle-1(2), Bangalore (`A0') Erred In Passing The Assessment Order Under Section 143(3) R.W.S 144C(13) Of The Income Tax Act, 1961 (`The Act) In The Manner Passed

For Respondent: Shri Padam Chand

Section 143(3)Section 14ASection 92B

made under section 14A of the Act amounting to Rs. 1,59,79,272 is excessive and bad in law. 6. Levy of interest under section 234C 6.1 The learned AO erred in levying interest under section 234C of the Act amounting to Rs.12 ... Appellant denies its liability to pay interest under section 234C. The Appellant prays accordingly.” 2. Ground nos. 1-2 are general in nature and does not require adjudication. The Ld.AR summarised that the appeal pertains to only three issues that are as under: i) Disallowance under corporate guarantee

Anchor Electricals Pvt. Ltd., Mumbai vs. Jt. CIT - Ccc- 7(2)`, Mumbai

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

ITA 4940/MUM/2018[2014-15]Status: DisposedITAT Mumbai13 Oct 2022AY 2014-15

Bench: Shri Amarjit Singh & Shri Rahul Chaudharyanchor Electricals Vs. Joint Commissioner Of Private Limited Income-Tax, Central 3Rd Floor, I-Think Techno Circle-7(2) Campus, Pokhran Road Room No.655, 6Th Floor, No.2, Thane (W), Aayakar Bhavan, M.K. 400607 Road, Mumbai - 400020 स्थायी लेखा सं./जीआइआर सं./ Pan/Gir No: Aaeca2190C Appellant .. Respondent

For Appellant: M.P. Lohia &For Respondent: Yogesh Kamat

Section 143(3)Section 234CSection 271(1)(c)Section 274

Anchor brand name, without appreciating the fact that the brand royalty cannot be compared with royalty for technical know-how. Levy of interest under section 234C of the Act 5. erred in levying interest under section 234C of the Act of INR 10,20,963 where interest under section 234C

Hewlett Packard (India) Software Operation Private Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

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

ITA 413/BANG/2022[2017-18]Status: DisposedITAT Bangalore03 Oct 2022AY 2017-18

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.413/Bang/2022 Assessment Year: 2017-18

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Shri Sumer Singh Meena, D.R

Section 192Section 195Section 37Section 40Section 92C

No.413/Bang/2022 Hewlett Packard (India) Software Operation Pvt. Ltd., Bangalore Page 5 of 32 3.6 The NFAC erred in the levying interest under section 234C of the Act on the assessed income instead of considering the returned income thereby levying an excess interest of INR 31,47,067. 4 Penalty proceedings

Ntt Data Fa Insurance Systems (India) Private Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

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

ITA 261/BANG/2021[2016-17]Status: DisposedITAT Bangalore03 Oct 2022AY 2016-17

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.261/Bang/2021 Assessment Year: 2016-17

For Appellant: Shri T. Suryanarayana, Sr. A.RFor Respondent: Shri Sumer Singh Meena, D.R

Section 143(3)Section 92C

No.261/Bang/2021 NTT Data FA Insurance Systems (India) Pvt. Ltd., Bangalore Page 4 of 37 24. The Ld. AO has erred in levying interest under section 234C of the Income Tax Act, 1961. 25. The Ld. AO has erred in initiating penalty proceedings under section 271(1)(c) of the Income

Life Insurance Corporation of India, Mumbai vs. Dy.Commissioner of Income Tax-3(2)(1), Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 1714/MUM/2022[2013-14]Status: DisposedITAT Mumbai29 Sept 2022AY 2013-14

Bench: Shri Kuldip Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blelife Insurance Corporation Of India V. Dcit – 3(2)(1) Central Office, F&A Department Room No. 608 3Rd Floor, West Wing Aayakar Bhavan, M.K. Road “Yogakshema” Jeevan Bima Marg Mumbai - 400020 Mumbai - 400021 Pan: Aaacl0582H Appellant Respondent Acit – 3(2)(1) V. M/S. Life Insurance Corporation Of India Central Office Room No. 674, 6Th Floor “Yogakshema” Jeevan Bima Marg Aayakar Bhavan, M.K. Road Nariman Point, Mumbai - 400021 Mumbai - 400020 Pan: Aaacl0582H Appellant Respondent

Section 115Section 44Section 80G

interest under section 234B of the Act 23. erred in confirming levy of interest under section 234B of the Act: Charging of interest under section 234C of the Act 24. erred in confirming levy of interest under section 234C of the Act, Charging of interest under section 234D

ACIT-3(2)(1), Mumbai vs. M/S Life Insurance Corporation of India, Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 1710/MUM/2022[2013-2014]Status: DisposedITAT Mumbai29 Sept 2022AY 2013-2014

Section 115Section 44Section 80G

Life Insurance Corporation of India, Mumbai vs. Deputy Commissioner of Income Tax-3(2)(1), Mumbai

ITA 1671/MUM/2022[2010-2011]Status: DisposedITAT Mumbai29 Sept 2022AY 2010-2011

Bench: Shri Kuldip Singh & Shri S. Rifaur Rahmanassessment Year: 2010-11 M/S. Life Insurance Dcit 3(2)(1), Corporation Of India, Room No.608, Central Office, Aayakar Bhavan, F&A Department, Maharshi Karve Road, Vs. 3Rd Floor, West Wing, New Marine Lines, “Yogakshema”, Mumbai - 400020 Jeevan Bima Marg, Mumbai – 400 021 Pan: Aaacl0582H (Appellant) (Respondent) Assessment Year: 2010-11 Acit 3(2)(1), M/S. Life Insurance Room No.674, 6Th Floor, Corporation Of India, Aayakar Bhavan, Central Office, M.K. Road, Vs. Yogakshema, Mumbai - 400020 Jeevan Bima Marg, Nariman Point, Mumbai – 400 005 Pan: Aaacl0582H (Appellant) (Respondent)

For Appellant: Shri Anish Thacker, A.RFor Respondent: Shri Jagadish Jangid, D.R

Section 147Section 14ASection 250Section 44Section 80G

interest under section 234B of the Act 16. erred in confirming levy of interest under section 234B of the Act; Charging of interest under section 234C of the Act 17. erred in confirming levy of interest under section 234C of the Act; Charging of interest under section 234D

Asst. Comm of Income Tax 3(2) (1), Mumbai vs. Life Insurance Corporation of India, Mumbai

ITA 1566/MUM/2022[2010-11]Status: DisposedITAT Mumbai29 Sept 2022AY 2010-11

For Appellant: Shri Anish Thacker, A.RFor Respondent: Shri Jagadish Jangid, D.R

Section 147Section 14ASection 250Section 44Section 80G

Hp Pps Services India Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle-3(1)(2), Bangalore

In the result the appeal filed by the assessee stands partly allowed

ITA 278/BANG/2021[2016-17]Status: DisposedITAT Bangalore29 Sept 2022AY 2016-17

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuit(Tp)A No. 278/Bang/2021 Assessment Year : 2016-17 M/S. Hp Pps Services India Pvt. Ltd., The Deputy No. 24, Salarpuria Commissioner Of Arena, Income Tax, Hosur Main Road, Circle 3 (1)(1), Adugodi, Vs. Bangalore. Bangalore – 560 030. Pan: Aadch5825N Appellant Respondent : Shri Padamchand Assessee By Khincha, Ca : Shri Binod Kumar Singh, Revenue By Cit Dr Date Of Hearing : 22-08-2022 Date Of Pronouncement : 29-09-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Assessment Order Dated 29/03/2021 Passed By National E-Assessment Centre, Delhi For A.Y. 2016-17 On Following Grounds Of Appeal. “The Appellant Submits That: I. Transfer Pricing The Grounds Mentioned Hereinafter Are Without Prejudice To One Another. 1. The Learned Assessing Officer ('Learned Ao'), Learned Transfer Pricing Officer ('Learned Tpo') & The Honourable Dispute Resolution Panel ('Hon'Ble Drp')

For Respondent: Shri Padamchand

date prescribed under Section 139(1) of the Act i.e. 30 November 2016. 19. The learned AO has erred in law in levying interest under Section 234C of the Act of INR 4,588,402 as against INR 3,875,685 determined as per the return of income

Novartis India Ltd, Mumbai vs. Addl CIT RG 7(1), Mumbai

In the result, appeal filed by the assessee is partly allowed as stated above

ITA 7644/MUM/2012[2008-09]Status: DisposedITAT Mumbai28 Sept 2022AY 2008-09

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Novartis India Limited Addl. Cit, Range 7(1) V. Aayakar Bhavan, M.K. Road Sandoz House, Dr. Annie Besant Road Worli, Mumbai - 400018 Mumbai Pan: Aaach2914F Appellant Respondent Assessee Represented By : Shri Rajan Vora & Shri Pranay Gandhi Revenue Represented By : Shri Rajneesh Yadav

Section 144C(5)Section 35DSection 92C(2)

credit amounting to Rs.1,55,05,715/- without giving any reasons for the same. GROUND NO. 13 The learned AO erred in charging interest under section 234C of Rs.12,51,546/- as against Rs. 617,293/- per ROI 6 M/s. Novartis India Limited GROUND NO. 14 The learned AO erred

Life Insurance Corporation of India, Mumbai vs. Dy.Commissioner of Income Tax-3(2)(1), Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 1717/MUM/2022[2017-18]Status: DisposedITAT Mumbai27 Sept 2022AY 2017-18

Bench: Shri Kuldip Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 115Section 44Section 80G

interest under section 234B of the Act 23. erred in confirming levy of interest under section 234B of the Act; Charging of interest under section 234C of the Act 24. erred in confirming levy of interest under section 234C of the Act. M/s. Life Insurance Corporation of India Charging