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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

Isdec India Private Limited, Milkhiram Market, Sakchi, Jamshedpur vs. Deputy Commissioner of Income Tax, Circle 1(1), Kolkata, Aayakar Bhawan, Chowringhee Square

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

ITA 730/KOL/2025[2023-24]Status: DisposedITAT Kolkata24 Jul 2025AY 2023-24

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(1)Section 234CSection 250

claimed in ROI) was determined due to short grant of TDS credit to the tune of Rs.2,69,033/- and consequential interest under section 234C of the Act. The above short grant of TDS of Rs.2,69,033/- was determined by virtue of Rule 37BA of the Income Tax Rules

Glitch Media Private Limited, Mumbai vs. Deputy Commissioner of Income Tax - 1(3)(1), Mumbai

In the result the appeal filed by the assessee stands partly

ITA 2178/MUM/2025[2020-21]Status: DisposedITAT Mumbai24 Jul 2025AY 2020-21

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

Section 139(1)Section 143(1)Section 143(3)Section 234ASection 234BSection 234CSection 250Section 270ASection 36(1)(va)Section 37(1)

erred in levying interest under section 234B of Rs.6,87,930 of the Act. 12. erred in levying interest under section 234C of the Act of Rs. 44,401 on the assessed income without appreciating that section 234C of the Act is applicable only on returned income

Sanjiv Soshil Mehta, Mumbai vs. Deputy Commissioner of Income Tax, Central Circle 5(2), Kautilya Bhavan

In the result, appeal of the assessee is allowed

ITA 2096/MUM/2025[2020-2021]Status: DisposedITAT Mumbai23 Jul 2025AY 2020-2021

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Anikesh Banerjee, Hon'Ble

For Appellant: Revenue byFor Respondent: Income-tax – 1, Mumbai
Section 143(1)Section 143(2)Section 143(3)Section 144BSection 263Section 90

payment of Fourth Instalment Net Tax Payable / (Refundable) (Rounded Off) Exempt income Dividend from Companies -Dividend from Mutual funds Total Computation on interest under section 234C Tax Liability after TDS Particulars Advance tax payable Period (months) Interest (INR) 15% of Tax liability after TDS by 15 June

Dadiba Kali Pundole, Mumbai vs. Deputy Commissioner of Incomem Tax -17(1), Mumbai

The appeal of the assessee is allowed

ITA 3265/MUM/2025[2023-24]Status: DisposedITAT Mumbai18 Jul 2025AY 2023-24

Bench: Shri Pawan Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri Amey Wagle & Shri AzimFor Respondent: 07.07.2025
Section 143Section 143(1)Section 154Section 194QSection 234Section 234CSection 246ASection 250

return of income. 12. The learned Commissioner of Income Tax (Appeals) erred in confirming the excess levy of interest under section 234C of the Act of Rs. 29,16,062/- as per the Intimation under section 143(1) as against Rs. 21,31,475/- as per Return of Income

Trumpf (India) Private Limited, Pune vs. Income Tax Officer, Ward 14(5), Pune

In the result, appeal of the assessee is dismissed

ITA 1448/PUN/2025[2010-11]Status: DisposedITAT Pune16 Jul 2025AY 2010-11

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं./Ita No.1448/Pun/2025 िनधा"रण वष" / Assessment Year: 2010-11 Trumpf (India) Private Limited, V The Income Tax Officer, Raisoni Industrial Park, S. Ward-14(5), Pune. S.No.276, Hissa No.1, Village Mann, Taluka – Mulshi, Pune – 411057. Maharashtra. Pan: Aacct8008J Appellant/ Assessee Respondent / Revenue Assessee By Shri Abdulkadir Jawadwala– Ar(Virtual) Revenue By Shri Akhilesh Srivastva – Addl.Cit(Dr) Date Of Hearing 10/07/2025 Date Of Pronouncement 16/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: The Assessee Has Filed An Appeal Against The Order Of Ld.Addl./Joint Commissioner Of Income Tax (Appeal)-12, Delhi Passed Under Section 250 Of The Income Tax Act, 1961 Dated 25.03.2025 For A.Y.2010-11, Emanating From The Order U/S.143(3) Of The Act, Dated 03.11.2024. The Assessee Has Raised The Following Grounds Of Appeal :

Section 143(3)Section 234CSection 250Section 271

facts of the case. 8. Levy of interest obligation: The learned DCIT has erred on the facts and in law by levying interest under section 234C and 244A of the Income Tax Act, 1961. 9. Each one of the above grounds of appeal is without prejudice to the other

Rajiv Trust, Mumbai vs. Deputy Commissioner of Income Tax, Mumbai

In the result, the appeal of the assessee is allowed

ITA 161/MUM/2025[2022-23]Status: DisposedITAT Mumbai15 Jul 2025AY 2022-23

Bench: Shri Pawan Singh& Ms. Padmavathy S

Section 111ASection 12ASection 143(1)Section 2Section 234CSection 254(1)

Finance Act. Therefore, the rate of surcharge applicable on income other than dividend income is 15%. As a result of such erroneous surcharge, interest under section 234C has also been levied at Rs. 7,641/-.” 2. At the outset of hearing, the learned Authorised Representative (ld. AR) of the assessee

Rajiv Trust, Mumbai vs. Deputy Commissioner of Income Tax, Mumbai

In the result, the appeal of the assessee is allowed

ITA 160/MUM/2025[2023-24]Status: DisposedITAT Mumbai15 Jul 2025AY 2023-24

Bench: Shri Pawan Singh& Ms. Padmavathy S

Section 111ASection 12ASection 143(1)Section 2Section 234CSection 254(1)

Finance Act. Therefore, the rate of surcharge applicable on income other than dividend income is 15%. As a result of such erroneous surcharge, interest under section 234C has also been levied at Rs. 7,641/-.” 2. At the outset of hearing, the learned Authorised Representative (ld. AR) of the assessee

Ksb Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle 3(4), Mumbai

In the result, all the grounds raised by the assessee are hereby allowed for statistical

ITA 1028/MUM/2024[2021-22]Status: DisposedITAT Mumbai09 Jul 2025AY 2021-22

Bench: Ms. Kavitha Rajagopal, Jm & Smt. Renu Jauhri, Am

For Appellant: Shri J. D. Mistri a/w. Shri Ketan VedFor Respondent: Shri Biswanath Das - CIT DR
Section 234ASection 234BSection 234CSection 250

Rs.1,44,28,612 and under section 234B of the Act to the extent of Rs.8,12,46,396. Excess-levy of interest under section 234C of the Act 10. The learned CIT (Appeals) erred in confirming the levy of excess interest under section 234C

Palam Rural Centre, Tiruppur vs. ACIT, Exemptions, Coimbatore

In the result, the appeal filed by the assessee is allowed for statistical purposes and the Stay Application filed by the assessee is dismissed as infructuous

ITA 1560/CHNY/2025[2018-19]Status: DisposedITAT Chennai01 Jul 2025AY 2018-19

Bench: Shri George George K & Shri S.R.Raghunathaआयकर अपील सं./Ita No.:1560/Chny/2025 & S.A.No.51Chny/2025 [Arising In Ita No.: 1560/Chny/2025] िनधा"रण वष" / Assessment Year:2018-19 Palam Rural Centre, The Asst. Commissioner Of Pethampalayam, Vs. Income Tax (Exemptions), Veerapandi S.O., Coimbatore. Tiruppur – 641 605. [Pan: Aaatp-2929-F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Shri. Edser Raj, Advocate ""थ" की ओर से/Respondent By : Ms. Sita Krishnamoorthy, J.C.I.T.

For Appellant: Shri. Edser Raj, AdvocateFor Respondent: Ms. Sita Krishnamoorthy, J.C.I.T
Section 11Section 12ASection 139

arriving at a Total Income of Rs.1,92,15,510/- and a demand of Rs.84,41,913/-. It may be noted that Interest under Section 234C was levied at Rs.3,43,663/-. :-8-: ITA No.:1560/Chny/2025 & S.A.No.51Chny/2025 6. Being aggrieved, the assessee filed a Return of Income u/s.119

Analytix Business Solution (I) Pvt. Ltd., Ahmedabad vs. The ITO, Ward-4(1)(1), Ahmedabad

In the result, appeal filed by the assessee is allowed

ITA 646/AHD/2025[2023-24]Status: DisposedITAT Ahmedabad30 Jun 2025AY 2023-24

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI T.R. SENTHIL KUMAR (Judicial Member)

For Appellant: Shri Rohan Thakkar, A.RFor Respondent: Shri Hargovind Singh, Sr. DR
Section 143Section 143(1)Section 234Section 234CSection 250Section 80J

Additional / Joint Commissioner Appeals as well as the assessing officer has erred on facts as well as in law in charging interest under section 234C of the Income Tax Act.” 3. The solitary issue in the present case is denial of deduction claimed by the assessee u/s. 80JJAA

Nirav Trust, Mumbai vs. Deputy Commissioner of Income Tax, Mumbai

In the result, the appeal of the assessee is allowed

ITA 2987/MUM/2025[2021-22]Status: DisposedITAT Mumbai19 Jun 2025AY 2021-22

Bench: Shri Vikram Singh Yadav & Ms. Kavitha Rajagopalassessment Year : 2021-22 Nirav Trust, Deputy Commissioner Of 2Nd Floor, Income Tax, Bajaj Bhawan, Vs. Circle-17(1), Jamnalal Bajaj Marg, Kautilya Bhavan, Nariman Point, Mumbai-400051. Mumbai-400021. Pan : Aactn7869E (Appellant) (Respondent) For Assessee : Shri M.A. Gohel For Revenue : Shri Leyaqat Ali Aafaqui Date Of Hearing : 17-06-2025 Date Of Pronouncement : 19-06-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Addl/Jcit(A)-4, Delhi [„Ld.Cit(A)‟], Dated 25-03-2025, Pertaining To Assessment Year (Ay) 2021-22, Wherein The Assessee Has Taken The Following Grounds Of Appeal:

For Appellant: Shri M.A. GohelFor Respondent: Shri Leyaqat Ali Aafaqui
Section 143(1)Section 208Section 234CSection 234C(1)

arisen in the month of March 2021 i.e. after 15-12-2020 and hence, the same is not to be considered for computing interest under Section 234C of the Act for instalment of Advance tax payable prior to the transaction of such short-term capital gains. The Appellant prays that

Employees Retirement System of Texas, Mumbai vs. Dy CIT (Int. Tax)-2(2)(1), Mumbai

The appeals are partly allowed

ITA 2155/MUM/2025[2022-23]Status: DisposedITAT Mumbai13 Jun 2025AY 2022-23

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Anish ThackarFor Respondent: Shri Satya Pal Kumar
Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 70Section 70(2)

against INR 55,547,350 as claimed by the Appellant in the return of income. 8. Erred in levying interest under section 234C of the Act amounting to INR 3,50,285, Initiating penalty proceedings under section 270A of the Act. 9. Erred in initiating penalty under section 270A ... against INR 9,47,66,743 as claimed by the Appellant in the return of income. 7. Erred in levying interest under section 234C of the Act amounting to INR 43,100. Initiating penalty proceedings under section 270A of the Act. 8. Erred in initiating penalty under section 270A

Fidelity Rutland Square Trust II Strategic Advisers Emerging Markets Fund, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation), Mumbai

The appeals are partly allowed

ITA 2127/MUM/2025[2022-23]Status: DisposedITAT Mumbai13 Jun 2025AY 2022-23
For Respondent: Shri Anish Thackar
Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 70Section 70(2)

against INR 55,547,350 as claimed by the Appellant in the return of income. 8. Erred in levying interest under section 234C of the Act amounting to INR 3,50,285, 9. Initiating penalty proceedings under section 270A of the Act. Erred in initiating penalty under section 270A ... against INR 9,47,66,743 as claimed by the Appellant in the return of income. 7. Erred in levying interest under section 234C of the Act amounting to INR 43,100. 8. Initiating penalty proceedings under section 270A of the Act. Erred in initiating penalty under section 270A

Fidelity Salem Street Trust Fidelity Sai Emerging Markets Index Fund, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation)-2(3)(1), Mumbai

The appeals are partly allowed

ITA 2126/MUM/2025[2022-23]Status: DisposedITAT Mumbai13 Jun 2025AY 2022-23

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Anish ThackarFor Respondent: Shri Satya Pal Kumar
Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 70Section 70(2)

against INR 55,547,350 as claimed by the Appellant in the return of income. 8. Erred in levying interest under section 234C of the Act amounting to INR 3,50,285, Initiating penalty proceedings under section 270A of the Act. 9. Erred in initiating penalty under section 270A ... against INR 9,47,66,743 as claimed by the Appellant in the return of income. 7. Erred in levying interest under section 234C of the Act amounting to INR 43,100. Initiating penalty proceedings under section 270A of the Act. 8. Erred in initiating penalty under section 270A

Fidelity Rutland Square Trust II Strategic Advisers Fid Emg Markets Fund, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation )2(3)(1), Mumbai

ITA 2125/MUM/2025[2022-23]Status: DisposedITAT Mumbai13 Jun 2025AY 2022-23
Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 70(2)

against INR 55,547,350 as claimed by the Appellant in the return of income. Erred in levying interest under section 234C of the Act amounting to INR 3,50,285, Initiating penalty proceedings under section 270A of the Act. Erred in initiating penalty under section 270A ... against INR 9,47,66,743 as claimed by the Appellant in the return of income. Erred in levying interest under section 234C of the Act amounting to INR 43,100. Initiating penalty proceedings under section 270A of the Act. Erred in initiating penalty under section 270A

Ishares Msci All Country Asia Ex Japan Etf(As A Successor to Ishares Msci All Country Asia Ex Japan Mauritius Co), Mumbai vs. DCIT (Int)-2(2)(2), Mumbai

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

ITA 2154/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

Section 143(3)Section 144C(13)

Rs.4,96,38,028 14. erred in levying interest under Section 234B of the Act amounting to Rs. 49,638,028; Levy of interest under section 234C of the Act - Rs.3,57,020 15. erred in levying interest under Section 234C of the Act amounting to Rs. 357,020; Initiation

Ishares Msci India Etf(As A Sucessor to Ishares India Index Maruitius Company), Mumbai vs. DCIT (Int)-2(2)(2), Mumbai

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

ITA 2153/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

erred in levying interest under Section 234B of the Act amounting to Rs. 49,638,028; Levy of interest under section 234C of the Act - Rs. 3,57,020 15. erred in levying interest under Section 234C of the Act amounting to Rs. 357,020; Initiation of penal proceedings under

Ishares Core Msci Em Imi Ucits Etf, Mumbai vs. DCIT (Int)-2(2)(2), Mumbai

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

ITA 2152/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

Rs.4,96,38,028 14. erred in levying interest under Section 234B of the Act amounting to Rs. 49,638,028; Levy of interest under section 234C of the Act - Rs.3,57,020 15. erred in levying interest under Section 234C of the Act amounting to Rs. 357,020; Initiation

Ishares Core Msci Total International Stock Etf (As A Successor to Ishares Core Total International Stock Mauritius Co ), Mumbai vs. Deputy Commissioner of Income Tax (International Taxation)-2(2)(2), Mumbai

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

ITA 2151/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

erred in levying interest under Section 234B of the Act amounting to Rs. 49,638,028; Levy of interest under section 234C of the Act - Rs. 3,57,020 15. erred in levying interest under Section 234C of the Act amounting to Rs. 357,020; Initiation of penal proceedings under

Ishares Msci Emerging Markets Etf (As A Successor to Ishares Emerging Markets Index Mauritius Co ), Mumbai vs. Deputy Commissioner of Income Tax (International Taxation)-2(2)(2), Mumbai

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

ITA 2150/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

Rs.4,96,38,028 14. erred in levying interest under Section 234B of the Act amounting to Rs. 49,638,028; Levy of interest under section 234C of the Act - Rs.3,57,020 15. erred in levying interest under Section 234C of the Act amounting to Rs. 357,020; Initiation