← All Phrases

“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

Jogpl Pvt Ltd, Uttar Pradesh vs. DCIT Circle-13(1) Delhi, Delhi

In the result, the appeal of the assessee is partly allowed for 14

ITA 1718/DEL/2022[2017-18]Status: DisposedITAT Delhi08 Oct 2025AY 2017-18

Bench: Shri C. N. Prasad & Shri M. Balaganeshjogpl Pvt. Ltd, Vs. Dcit, Plot No. 15, Knowledge Circle-13(1), Park-2, Greater Noida, Delhi Up 2011306 (Appellant) (Respondent) Pan: Aaace0169K Assessee By : Shri M. K. Gupta, Adv Revenue By: Shri S. K. Jadav, Cit Dr Date Of Hearing 17/07/2025 Date Of Pronouncement 08/10/2025

For Appellant: Shri M. K. Gupta, AdvFor Respondent: Shri S. K. jadav, CIT DR
Section 143(3)Section 144C(5)Section 92C

decided. The chargeability of interest under section 234B and 234D of the Act is consequential in nature. With regard to interest under section 234C of the Act, the law is well settled that the same JOGPL Pvt. Ltd shall be charged only on the returned income

Bidyut Prakas Bhattacharya, Kolkata vs. I.T.O., Ward - 52(1), Kolkata

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

ITA 2016/KOL/2024[2018-2019]Status: DisposedITAT Kolkata07 Oct 2025AY 2018-2019

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 139(1)Section 143(1)Section 154Section 234ASection 234BSection 234CSection 250Section 90

well as on law, the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC) has erred in confirming the levy of interest under section 234C amounting to Rs. 32,317. 6. That your appellant begs your leave to urge any additional ground or modify any grounds ... impugned levy of interest under section 234B amounting to Rs. 1,72,773 is liable to be summarily rejected. 4. Impugned levying interest under section 234C amounting to Rs. 32,317. The Learned Deputy Director of Income Tax, CPC, Bengaluru, has passed the order under section 154 in ignoring

Sp Armada Oil Exploration Private Limited, Mumbai vs. Deputy Commissioner of Income Tax- Circle 3(3)(1), Mumbai

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

ITA 6575/MUM/2024[2021-22]Status: DisposedITAT Mumbai06 Oct 2025AY 2021-22

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailsp Armada Oil Exploration Private Limited 404, Trade Centre, Bandra Kurla Complex, Bandra (East), Mumbai 400051. Pan: Aaqcs7983P ............... Appellant

For Appellant: Shri Mukesh Butani a/w Shri Pratik PoddarFor Respondent: Shri. Pravin Salunkhe & Shri Aditya M. Rai
Section 143(2)Section 143(3)Section 234ASection 253(1)Section 92C(1)Section 92C(2)Section 92C(3)

section 234B of the Act. 13. On facts and circumstances of the case and in law, the learned AO erred in levying interest under section 234C of the Act. 14. On facts and circumstances of the case and in law, the learned AO erred in initiating penalty proceedings under Section ... section 234A and 234B which is consequential in nature, hence separate tax effect is not calculated Ground 13: This ground relates to charging interest under section 234C of the Act and its tax effect is INR 24,33,595. Ground 14: This ground relates to initiation of penalty proceedings, hence

Aptiv Components India P.Ltd (Formerly Known As Delphi Automotive Systems P.Ltd), New Delhi vs. ACIT, Circle-1(1), New Delhi

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

ITA 2082/DEL/2022[2018-19]Status: DisposedITAT Delhi01 Oct 2025AY 2018-19

Bench: Shri M. Balaganesh & Shri Anubhav Sharmam/S Aptive Components India Vs. Acit, Private Limited (Formerly Known Circle-1(1), As M/S Delphi Automotive New Delhi System Private Limited), P-24, Green Park Extension, New Delhi (Appellant) (Respondent) Pan: Aaacd0226F Assessee By : Shri Ajay Vohra, Sr. Adv Shri Neeraj Jain, Adv Ms. Richa Aggarwal, Adv Revenue By: Shri Amit Kumar Singh, Sr. Dr Date Of Hearing 04/07/2025 Date Of Pronouncement 01/10/2025

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Amit Kumar Singh, Sr. DR
Section 143(3)Section 144C(5)Section 92C

234C of the Act. With regard to interest under section 234B of the Act, the same is consequential in nature. With regard to interest under section 234C of the Act, the law is very well settled that the interest could be charged only on the returned income

Shell International Petroleum Company Limited, Mumbai vs. Deputy Commissioner of Income Tax International Taxation -4(2)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 4712/MUM/2023[2021-22]Status: DisposedITAT Mumbai30 Sept 2025AY 2021-22

Bench: Smt. Beena Pillai & Smt. Renu Jauhrishell International Dy. Commissioner Of Petroleum Company Income –Tax (International Limited Taxation) 4(2)(1), Mumbai C/O B S R & Co. Llp, 2Nd 17Th Floor, Room No. 1708, Air Vs. Floor, Lodha Excelus, India Building, Nariman Point, Apollo Mills Compound, Mumbai N.M. Joshi Marg, Mahalakshmi, Mumbai 400011 स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaics0357B (Appellant) (Respondent) निर्ााररतीकीओरसे/ Assessee By: Shri. Madhur Agrawal/ Ms. Reema Grewal /Revenue By: Shri Satya Pal Kumar Cit (Dr) Date Of Hearing 06.08.2025 Date Of Pronouncement 30.09.2025 आदेश/O R D E R Per Renu Jauhri [A.M]: This Appeal Is Filed By The Assessee Against The Order Of Dy. Cit (It), Mumbai Dated 27.09.2023 Passed As Per The Directions Of The Dispute Resolution Panel (Drp) U/S. 144C(5) Of The Income Tax Act, 1961 [Hereinafter Referred To As "Act"] For Assessment Year [A.Y.] 2021-22. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri. Madhur Agrawal/For Respondent: Shri Satya Pal Kumar CIT (DR)
Section 143(3)Section 144C(13)Section 144C(5)Section 153Section 2(24)Section 9(1)(vi)

facts and circumstance of the cate P a g e | 4 ITA No. 4712/Mum/2023 Ay 2021-22 Shell International Petroleum company Limited Interest under section 234C of the Act 16. Erred in levying interest under section 234C of the Act without appreciating the facts and circumstances of the case Incorrect

Mahindra and Mahindra Limited (As Sucessor to Mahindra Two Wheelers Limited Which in Turn Is Sucessor to Mahindra Trucks and Buses Limited), Mumbai vs. Deputy Commissioner of Income Tax Circle 2(2)(1), Mumbai

ITA 4964/MUM/2025[2018-19]Status: DisposedITAT Mumbai25 Sept 2025AY 2018-19
Section 115JSection 143(1)Section 143(3)Section 234ASection 234CSection 250Section 254(1)Section 270ASection 28Section 37

directed to delete the interest charged or appropriately reduce interest under sections 234A, 234B of the Act, as per law, and interest under section 234C be restricted to amount as per Income tax return filed. 4. Initiation of penalty proceeding under section 270A of the Act a. On the facts

Technip India Limited, New Delhi vs. ACIT, Spl Range-9, New Delhi

In the result, Appeal No.6390/Del/2017 is partly allowed as per above terms

ITA 9852/DEL/2019[2015-16]Status: DisposedITAT Delhi17 Sept 2025AY 2015-16

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarita No. 6390/Del/2017 Assessment Year: 2013-14 Ita No. 9852/Del/2019 Assessment Year: 2015-16 Technip Energies India Vs. Additional Commissioner Of Limited, ( Formerly Known As Income Tax, Technip India Limited), Special Range-9, A-4, Sector 1, Institutional New Delhi Area, Noida – 201 301 Pan No. Aaack3349R (Appellant) (Respondent)

For Appellant: Shri Vishal Kalra, Adv., Shri Yishu GoelFor Respondent: Shri Dharm Veer Singh, CIT (DR)
Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 250Section 92C

adjustments; 18. That on the facts and in the circumstances of the case and in law, the learned AO has erred in charging interest under section 234C of the Act without recording any satisfactory reasons for the same; and 19. That on the facts and in the circumstances

Technip India Ltd., Noida vs. Addl.CIT, Special Range- 9, New Delhi

In the result, Appeal No.6390/Del/2017 is partly allowed as per above terms

ITA 6390/DEL/2017[2013-14]Status: DisposedITAT Delhi17 Sept 2025AY 2013-14

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarita No. 6390/Del/2017 Assessment Year: 2013-14 Ita No. 9852/Del/2019 Assessment Year: 2015-16 Technip Energies India Vs. Additional Commissioner Of Limited, ( Formerly Known As Income Tax, Technip India Limited), Special Range-9, A-4, Sector 1, Institutional New Delhi Area, Noida – 201 301 Pan No. Aaack3349R (Appellant) (Respondent)

For Appellant: Shri Vishal Kalra, Adv., Shri Yishu GoelFor Respondent: Shri Dharm Veer Singh, CIT (DR)
Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 250Section 92C

adjustments; 18. That on the facts and in the circumstances of the case and in law, the learned AO has erred in charging interest under section 234C of the Act without recording any satisfactory reasons for the same; and 19. That on the facts and in the circumstances

Rain Cements, Hyderabad vs. DCIT., Circle-3(1), Hyderabad

In the result, appeal of the Assessee is dismissed

ITA 540/HYD/2025[2015-16]Status: DisposedITAT Hyderabad12 Sept 2025AY 2015-16

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: Sri Deepak Chopra, AdvocateFor Respondent: Sri Madan Mohan Meena, Sr. AR
Section 115Section 115JSection 143(1)Section 234CSection 246A

granting the appropriate MAT credit under section 115JAA of the Act. RE: CONSEQUENTIAL GROUNDS 14. That the CPC erred in enhancing interest under section 234C of the Act. 4 ITA.No.540/Hyd./2025 The above grounds are without prejudice to each other. The Appellant craves leave to add, withdraw, alter

Jasmina Trust, New Delhi vs. Deputy Commissioner of Income Tax, New Delhi

ITA 2209/DEL/2025[2021-22]Status: DisposedITAT Delhi12 Sept 2025AY 2021-22

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Smt. Vasanti Patel, AdvocateFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 11Section 12ASection 143(1)Section 167(1)Section 167BSection 234C

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES: A : NEW DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI

JCIT, Bangalore vs. M/S Hewlett Packard India Sales P. Ltd., Bangalore

In the result appeal of the ld AO is dismissed and Assessee is partly allowed

ITA 1252/BANG/2015[2010-11]Status: DisposedITAT Bangalore08 Sept 2025AY 2010-11

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2010-11

For Appellant: Shri Percy Pardiwala, Sr. AdvocateFor Respondent: Shri Shivanand Kalakeri, CIT(DR)(ITAT)
Section 143(3)Section 144CSection 40

1252/Bang/2015 Page 7 of 70 10.4 The CIT(A) has erred in law and on facts by not directing the AO to consider interest under section 234C of the Act as per the return of income filed by the Company. 10.5 The CIT(A) has erred

Hewlett Pakcard India Sales Private Limited, Bangalore vs. JCIT, Bangalore

In the result appeal of the ld AO is dismissed and Assessee is partly allowed

ITA 1245/BANG/2015[2010-11]Status: DisposedITAT Bangalore08 Sept 2025AY 2010-11

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2010-11

For Appellant: Shri Percy Pardiwala, Sr. AdvocateFor Respondent: Shri Shivanand Kalakeri, CIT(DR)(ITAT)
Section 143(3)Section 144CSection 40

1252/Bang/2015 Page 7 of 70 10.4 The CIT(A) has erred in law and on facts by not directing the AO to consider interest under section 234C of the Act as per the return of income filed by the Company. 10.5 The CIT(A) has erred

Voith Hydro Pvt Ltd, Noida vs. ACIT Circle-25(1), Delhi

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

ITA 5722/DEL/2024[2022-23]Status: DisposedITAT Delhi28 Aug 2025AY 2022-23

Bench: Shri Prakash Chand Yadav & Shri Manish Agarwalvoith Hydro Private Limited Assistant Commissioner A20 & 21, Noida Sector-59, Of Income Tax, Uttar Pradesh-201301. Vs. Circle-25(1), New Delhi. Pan-Aabcv5041J (Appellant) (Respondent)

Section 143(1)Section 234BSection 234CSection 243BSection 243CSection 250

Ground of Appeal No. 6: Levy of interest under section 243C of the Act - Rs.1,27,962 6 erred in levying interest under section 234C of the Act amounting to Rs.1,27,962; The above grounds of appeal are mutually exclusive and without prejudice to each other. The Appellant craves

J P Morgan Services India Pvt Ltd, Mumbai vs. DCIT Circle 2(2)(1), Mumbai

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

ITA 6563/MUM/2024[2021-22]Status: DisposedITAT Mumbai26 Aug 2025AY 2021-22

Bench: Shri Sandeep Singh Karhailshri Girish Agrawalj P Morgan Services India Private Limited Tower A Blk 9, Tower B Blk 10, Tower C Blk 11, Nirlon Knowledge Park, Western Express Highway, Goregaon East, Mumbai Suburban, ............... Appellant 400063. Pan : Aabcd0503B V/S Deputy Commissioner Of Income-Tax, Circle 2(2)(1), ……………… Respondent Aayakar Bhawan, Maharshi Karve Road, New Marine Lines, Churchgate, Mumbai-400020. Assessee By : Shri Fenil Bhatt Revenue By : Ms. Neena Jeph, Cit.Dr

For Appellant: Shri Fenil BhattFor Respondent: Ms. Neena Jeph, CIT.DR
Section 143(3)Section 144BSection 144CSection 144C(12)Section 144C(13)Section 144C(5)Section 153Section 92D

section 234B of the Act. 4 17. On the facts and in the circumstances of the case, the Ld.AO has erred in levying interest under section 234C of the Act. 18. On the facts and in the circumstances of the case and in law, the Ld. AO has erred

M V Subramanian Family Trust, Chennai vs. ITO, Ncw-1(1), Chennai

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

ITA 1087/CHNY/2025[2021-22]Status: DisposedITAT Chennai25 Aug 2025AY 2021-22

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 1087/Chny/2025 िनधा"रण वष"/Assessment Year:2021-22 M/S. M V Subramanian Family The Income Tax Officer, Trust, Non-Corporate Ward 1(1), 10, Valliammai Achi Road, Vs. Chennai. Kotturpuram, Chennai – 600 085. Pan: Aaetm 9151C (""यथ"/Respondent) (अपीलाथ"/Appellant) अपीलाथ" क" ओर से/Appellant By : Shri Ashwin, Ca ""यथ" क" ओर से/Respondent By : Ms. Anitha, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 24.07.2025 घोषणा क" तारीख/Date Of Pronouncement : 25.08.2025

For Appellant: Shri Ashwin, CAFor Respondent: Ms. Anitha, Addl.CIT
Section 111ASection 112ASection 143(1)Section 154Section 2Section 234BSection 234C

case and in law, the Ld. Respondent has erred in levying interest under sections 234B and 234C of the Act. 3.2. The Interest under section 234C has been erroneously levied at INR 5,813 by disregarding the fact that the same is required to be levied only on the returned

Bhupesh Sharma, New Delhi vs. ITO, New Delhi

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

ITA 3083/DEL/2025[2018-19]Status: DisposedITAT Delhi20 Aug 2025AY 2018-19

Bench: Shri M. Balaganeshbhupesh Sharma, Vs. Ito, House No. 1-202, Ward-36(1), Prashant Vihar, Rohini, Delhi Sector-16, New Delhi Pan: Asops8305C

For Appellant: Shri Raghav Sharma, CAFor Respondent: Shri Manoj Kumar, Sr. DR
Section 115Section 147Section 148Section 234ASection 234BSection 234CSection 69A

actual date of filing the return. The levy of interest under section 234B of the Act is consequential in nature. With regard to interest under section 234C of the Act, the law is well settled that the same shall be charged only on the returned income

Procter and Gamble Health Private Limited, Mumbai vs. The Pr. Commissioner of Income Tax -8, Mumbai

In the result, appeal of the assessee is allowed

ITA 2326/MUM/2025[2018-19]Status: DisposedITAT Mumbai14 Aug 2025AY 2018-19

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

For Appellant: Ms. Aarti Vissanji & Shri Ajay BhandariFor Respondent: Shri R A Dhyani, CIT D/R
Section 143(3)Section 144BSection 263Section 40Section 50CSection 56(2)(x)Section 68

assessed tax Advance tax paid Shortfall in payment of advance tax as compared to 90% of assessed tax Interest Add: Interest under section 234C of the Act Due date of installement on or before 15.06.2017, being 15% of assessed tax on or before 15.09.2017, being 45% of assessed

M/S. Bodal Chemicals Ltd., Ahmedabad vs. The Dy.CIT, Circle-1, Ahmedabad

In the result, the appeals being IT(SS)A No

ITA 318/AHD/2022[2009-10]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2009-10

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

For Appellant: Shri S.S. Nagar, ARFor Respondent: Shri Kamlesh Makwana, CIT-DR and Shri B.P. Srivastava, Sr.DR
Section 115JSection 132(1)Section 139(1)Section 139(5)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153A(1)(a)Section 153A(1)(b)

Assessing Officer not to charge interest under Section 234B on returned income for any delay in depositing self assessment tax. As regards interest under Section 234C of the Act the same is always levied on return income, hence the CIT(A) rightly directed the Assessing Officer to levy such interest

Ciena India Private Limited, Delhi vs. Deputy Commissioner of Income Tax, Circle 4(2), Delhi

Accordingly, Ground No. 2 raised by the assessee is allowed

ITA 3715/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Jul 2025AY 2020-21

Bench: Shri Ramit Kochar & Ms. Madhumita Royciena India Private Vs. Dcit, Circle 4(2) Limited, Co Kochhar & C.R. Building, Co. Law Office, Suite No. Delhi – 110002 1120-1121, 11Th Floor, Tower A, Dlf Towers Jasola, New Friends Colony S.O Zakir Nagar So, South East, Delhi – 110025, "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaccc6131B Appellant .. Respondent

For Appellant: Sh. Yishu Goel, AdvFor Respondent: Sh. S.K. Jadhav, CIT. DR
Section 143(3)Section 144BSection 144C(1)Section 234ASection 234CSection 36(1)(va)Section 43B

amounting to INR 7,40,715), 234B of the Act (amounting to INR 1,30,73,330) and increasing the interest under Section 234C (amounting to INR 7,49,340) of the P a g e | 3 Ciena India Private Limited (AY: 2020-21) That the above grounds are independent

Portescap India Private Limited, Mumbai vs. DCIT Circle 2(3)(1), Mumbai

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

ITA 6749/MUM/2024[2021-22]Status: DisposedITAT Mumbai28 Jul 2025AY 2021-22

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 143(3)Section 153Section 92C(3)

given to the Ld. AO to vacate the interest levied u/s 234B on disposal of appeal. 9. Ground No.9: Incorrect computation of interest under section 234C of the Act On the facts and in the circumstances of the case and in law, the Ld. AO erred in computing and levying