“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

Thermo Fisher Scientific India P. Ltd, Mumbai vs. DCIT 15(3)(1), Mumbai

ITA 7294/MUM/2018[2014-15]Status: DisposedITAT Mumbai02 Jan 2026AY 2014-15

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR

Section 143(3)Section 144C(13)Section 144C(5)Section 32(1)

Accordingly, Ground No.12 raised in assessee's appeal is allowed. 56. Grounds No.13-15, raised in assessee's appeal, pertain to the levy of interest under section 234C, 234D and 244A of the Act, which are consequential in nature. Therefore, the same need no separate adjudication. 57. Ground No.16 raised

Thermo Fisher Scientific India P. Ltd, Mumbai vs. DCIT 15(3)(1), Mumbai

In the result, the appeal by the assessee for the assessment year 2014-

ITA 7393/MUM/2017[2013-14]Status: DisposedITAT Mumbai02 Jan 2026AY 2013-14

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR

Section 143(3)Section 144C(13)Section 32(1)

Grounds No.13-15, raised in assessee’s appeal, pertain to the levy of interest under section 234C, 234D and 244A of the Act, which are consequential in nature. Therefore, the same need no separate adjudication. 57. Ground No.16 raised in assessee’s appeal pertains to the initiation of penalty proceedings under

Thermo Fisher Scientific India P. Ltd, Mumbai vs. DCIT 15(3)(1), Mumbai

ITA 577/MUM/2017[2012-13]Status: DisposedITAT Mumbai02 Jan 2026AY 2012-13

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR

Section 143(3)Section 144C(13)Section 144C(5)Section 32(1)

Thermo Fisher Scienftific India P. Ltd, Mumbai vs. DCIT 15(3)(1), Mumbai

In the result, the appeal by the assessee for the assessment year 2014-

ITA 1236/MUM/2016[2011-12]Status: DisposedITAT Mumbai02 Jan 2026AY 2011-12

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR

Section 143(3)Section 144C(13)Section 32(1)

Syntel Private Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 11(2)(2), Mumbai

Accordingly, Ground No. 3 & 4 raised by the Assessee is allowed for statistical purposes

ITA 6863/MUM/2025[2018-19]Status: DisposedITAT Mumbai01 Jan 2026AY 2018-19

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

For Appellant: Shri Ketan Ved &For Respondent: Shri Arun Kanti Datta

Section 115JSection 143(3)Section 144BSection 234CSection 37

Appellant, thereby not granting the Appellant an adequate opportunity of being heard and thus violating the principles of natural justice. Consequential levy of interest under section 234C of the Act 7. The leaned CIT(A) erred in confirming the levy of interest under section 234C of the Act amounting ... Ground No.6 raised by the Assessee is dismissed as not pressed. 13. Ground No.7 raised by the Assessee pertaining to levy of interest under Section 234C of the Act is disposed off as being consequential in nature. 14. In terms of paragraph 9 to 13 above, the present appeal preferred

Evry India Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle-2(2)(1), Bangalore

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

ITA 837/BANG/2025[2013-14]Status: DisposedITAT Bangalore31 Dec 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2013-14

For Appellant: Shri Nitin Surana, ARFor Respondent: Shri N Balusamy, JCIT (DR)

Section 234CSection 37Section 43ASection 44A

same does not require any separate adjudication. Likewise, the ground No. 3 of the assessee’s appeal pertains to levy of interest under section 234C of the Act, which is consequential in nature and the same Page 2 of 11 does not require any separate adjudication. Hence, the Ground

Deloitte Haskins and Sells LLP, Mumbai vs. Assistant Commissioner of Income Tax, Circle 16(2), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 351/MUM/2024[2017-18]Status: DisposedITAT Mumbai30 Dec 2025AY 2017-18

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri P.J. Pardiwala, Sr. AdvocateFor Respondent: Shri Krishna Kumar Sr. DR

Section 143(3)Section 37(1)Section 40

grant full credit for tax deducted at source as claimed by it and to re-compute its tax liability accordingly. 5:0 Interest under section 234C 5:1 The NFAC/CIT(A) erred in not directing the AO to re-compute the interest under section 234C after considering

Deloitte Haskins and Sells LLP, Mumbai vs. Assistant Commissioner of Income Tax, Circle 16(2), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 350/MUM/2024[2013-14]Status: DisposedITAT Mumbai30 Dec 2025AY 2013-14

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri P.J. Pardiwala, Sr. AdvocateFor Respondent: Shri Krishna Kumar Sr. DR

Section 143(3)Section 37(1)Section 40

Deloitte Haskins and Sells LLP, Mumbai vs. Assistant Commissioner of Income-Tax, Mumbai

In the result, appeal of the assessee is partly allowed

ITA 320/MUM/2024[2015-16]Status: DisposedITAT Mumbai30 Dec 2025AY 2015-16

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri P.J. Pardiwala, Sr. AdvocateFor Respondent: Shri Krishna Kumar Sr. DR

Section 143(3)Section 37(1)Section 40

Deloitte Haskins and Sells LLP, Mumbai vs. Assistant Commissioner of Income-Tax, Mumbai

ITA 319/MUM/2024[2016-17]Status: DisposedITAT Mumbai30 Dec 2025AY 2016-17

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri P.J. Pardiwala, Sr. AdvocateFor Respondent: Shri Krishna Kumar Sr. DR

Section 143(3)Section 40

Adp Private Limited, Hyderabad, Telangana vs. DCIT., Circle 1(1), Hyderabad, Telangana

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

ITA 332/HYD/2025[2021-22]Status: DisposedITAT Hyderabad10 Dec 2025AY 2021-22

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 153Section 195(2)Section 40

Consequential grounds 20.1 Without prejudice to the above grounds, on the facts and circumstances of the case, the Ld. AO erred in computing interest under section 234C of the Act on the assessed income instead of on the income returned by the Appellant. 20.2 The Ld. AO has erred

Concentrix Catalyst Technologies Private Limited, Hyderabad vs. DCIT., Circle - 1(1), Hyderabad

ITA 963/HYD/2024[2020-21]Status: DisposedITAT Hyderabad05 Dec 2025AY 2020-21

For Appellant: Shri D Prabhakar Reddy, AdvocateFor Respondent: : Dr. Narendra Kumar Naik, CIT(DR)

Section 143(3)Section 144C(13)Section 144C(5)Section 153

Form 26AS as per the OGE dated 07 February 2024 pursuant to the order of Hon'ble CIT(A). 19. erred in levying interest under section 234C of the Act in the impugned order. 20. erred in initiating penalty proceedings under section 270A of the Act against the Appellant without

Fluor Daniel India Private Limited, India vs. The Deputy Commissioner of Income Tax, Circle 7(1), Cr Building, Ip Estate, New Delhi, India

Appeal is allowed

ITA 3481/DEL/2025[2022-23]Status: DisposedITAT Delhi02 Dec 2025AY 2022-23

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

For Appellant: Sh. Vishal Kalra, Adv. &For Respondent: Ms. Ankush Kalra, Sr. DR

Section 139(1)Section 143(1)Section 234C

circumstances of the case, the CPC has grossly erred in levying and the Ld. ADDL/JCIT (A) in upholding the incorrect computation of interest under section 234C of the Act in the intimation order passed under Section 143(1) of the Act.” 3 Fluor Daniel India Pvt. Ltd. 4. Suffice

Kae Capital Fund, Mumbai vs. ITO Ward 25(1)(1), Mumbai

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

ITA 3752/MUM/2025[2020-21]Status: DisposedITAT Mumbai27 Nov 2025AY 2020-21

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailkae Capital Fund, 74Ab, Jolly Maker Chambers Ii, Vinay Shah Marg, Mumbai – 400021 ............... Appellant Pan : Aabtk9875E V/S Income Tax Officer, Ward – 25(1)(1)., ……………… Respondent Kautilya Bhavan, Bkc, Mumbai

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Hemanshu Joshi, Sr.DR

Section 10Section 10(35)Section 115USection 143(1)Section 154Section 250

therefore eligible for the exemption for the relevant year under consideration. 5. Ground No. 5: Erred in not deleting the levy of interest under section 234C of the Act 5.1. The Ld. CIT(A) failed to appreciate that, as per the provisions of the section 234C of the Act, interest ... returned income, and not on the assessed income. 5.2. The Ld. CIT(A) erred in upholding the action of the CPC in levying interest under Section 234C through the order passed under section 154 read with Section 143(1) of the Act. The Ld. CIT(A) incorrectly treated the levy

Bny Mellon International Operations (India) Pvt Ltd, Pune vs. I.T.O, CPC Bangaluru, Banguluru

ITA 2706/PUN/2024[2021-22]Status: DisposedITAT Pune26 Nov 2025AY 2021-22

Bench: Shri Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Nitesh S. Joshi, AdvocateFor Respondent: Shri Amol Khairnar, CIT-DR

Section 143(1)Section 143(1)(a)Section 143(3)Section 234CSection 250

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE “A” BENCH : PUNE BEFORE SHRI MANISH BORAD, ACCOUNTANT MEMBER & SHRI VINAY BHAMORE, JUDICIAL

Nemi Chand, Gudur vs. ITO., Ward-1, Gudur

In the result, appeal filed by the assessee is partly allowed in terms of our aforesaid observations

ITA 1288/HYD/2025[2018-19]Status: DisposedITAT Hyderabad26 Nov 2025AY 2018-19

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1288/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2018-19) Nemi Chand, Vs. Income Tax Officer, 1-2-8/11A, 302, 3Rd Floor, Ward-1, Srinivas Street No.1, Guduru. Himayat Nagar, Hyderabad, Telangana. Pan: Achpr2242L (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Sri Sridhar Jhawar, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 12/11/2025 घोषणा की तारीख/Date Of 26/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 13/06/2025 Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 143(3) R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “Act”), Dated 23/04/2021 For The Assessment Year 2018-19. The Assessee Has 2 Nemi Chand Vs. Ito Assailed The Impugned Order On The Following Grounds Of Appeal Before Us: 1. “Whether On The Facts & Circumstances Of The Case & In Law Whether The Order Of The Learned Commissioner Of Income Tax Was Pervasive In Considering The Income From Capital Gains As Business Income In Terms Of Provisions Of Section 2(14) Read With Section 2(47) 2. Whether On The Facts & Circumstances Of The Case & In Law. Whare Capital Gain Was Invested In Purchase/Construction Of Residential House Within Time Limit Prescribed Under Section 2 54(1), Assessment Order Allowing Assesses Claim Under Section 54 Could Not Be Treated As Erroneous & Prejudicial To Interest Of Revenue Only Because Capital Gain Was Not Deposited In Capital Gain Account Scheme. 3. Any Other Ground (If Any) That May Be Urged At The Time Of Hearing.”

For Appellant: Sri Sridhar Jhawar, CAFor Respondent: Dr. Sachin Kumar, Sr. AR

Section 143(3)Section 2Section 2(14)Section 2(47)Section 54

grounds of appeal no. 5 & 6 are dismissed. 6.3 Ground of appeal No. 7: The ground of appeal No. 7 relates to charging interest under section 234C. 6.3.1 This ground pertains to appellant's contention that AO wrongly charged interest 234C of the Act. Charging of such interest is consequential

Microsoft Corporation (India) Private Limited, New Delhi vs. Principal Commissioner of Income Tax, Delhi

In the result, appeal filed by the assessee is allowed

ITA 2933/DEL/2025[2019-20]Status: DisposedITAT Delhi26 Nov 2025AY 2019-20

Section 143(1)Section 143(3)Section 154Section 263

order, the assessee was not granted full credit of TDS, this being mistake apparent from the record is being rectified. 3. Levy of interest under section 234C of the Act:- Vide the final order, the interest under section 234C was levied on assessed income and not on returned income. This

International Specialty Products (India) Private Limited, Mumbai vs. The Deputy Commissioner of Income Tax, Circle 15(1)(2), Mumbai

In the result, appeal of the assessee is allowed

ITA 5336/MUM/2025[2020-21]Status: DisposedITAT Mumbai11 Nov 2025AY 2020-21

Bench: Shri Pawan Singh & Smt. Renu Jauhri

For Appellant: Shri Ninad PatadeFor Respondent: Shri Virabhadra Mahajan- Sr. DR

Section 234CSection 244ASection 250Section 270ASection 80G

prays that the Assessing Officer be directed to delete the disallowance of INR 19,05,673 under section 80G of the Act. 2. Interest under section 234C of the Act 2.1 The learned CIT(A) erred in confirming the interest amounting to INR 22,196 under section 234C ... learned CIT(A) erred in not appreciating that the interest under section 234C of the Act to be calculated on shortfall in deposit of advance tax based on the returned income and not on the assessed income. 2.3 The Appellant prays that the Assessing Officer be directed to delete interest

Ravi Shroff, Mumbai vs. Assistant Commissioner of Income Tax - 25(3), Mumbai, Bandra (East)

In the result, all remaining ground are allowed with the aforesaid directions

ITA 4186/MUM/2023[2015-16]Status: DisposedITAT Mumbai07 Nov 2025AY 2015-16

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 234BSection 234CSection 250Section 254(1)Section 28Section 28(1)

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 treating the same as compensatory, without appreciating the fact that interest under section 234C ought to be levied only

Mirae Asset Capital Markets (India) Private Limited, Mumbai vs. Income Tax Officer, Ward 4(3)(1), Mumbai

The appeal of the assessee is allowed

ITA 2099/MUM/2025[2020-21]Status: DisposedITAT Mumbai04 Nov 2025AY 2020-21

Bench: Shri Amit Shukla, Jm& Ms Padmavathy S, Am

For Appellant: Shri Pratik Poddar, & Shreyas SardesaiFor Respondent: 14.10.2025

Section 143(1)Section 143(1)(a)Section 14ASection 234CSection 250

adjudicating on the ground of appeal raised in relation to the aforesaid disallowance. 3 Mirae Asset Capital Markets (India) Pvt Ltd Interest under section 234C of the Act (Rs 40,221): 8. On facts and circumstances of the case and in law, the learned CPC / CIT(A) has erred