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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

DCIT, Cir-8(3)(1), Mumbai vs. M/S. Tata Aig General Insurance Co. Ltd., Mumbai

ITA 1834/MUM/2023[2016-17]Status: DisposedITAT Mumbai30 Oct 2024AY 2016-17

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Madhur Agrawal, AdvocateFor Respondent: Shri Biswanath Das, CIT DR
Section 10(15)(iv)Section 101A(7)Section 143(3)Section 32Section 37(1)Section 40Section 43BSection 44

facts and circumstances of the case and in law, ought to have held that learned AO erred in levying interest under section 234C of the Act of Rs 1,05,295 instead of Rs 11,561 considered by the Appellant in the revised return of income dated 29 March

M/S Tata Aig General Insurance Co.Ltd., Mumbai vs. ACIT - 8(3)(1), Mumbai

ITA 1816/MUM/2023[2017-18]Status: DisposedITAT Mumbai30 Oct 2024AY 2017-18
Section 10(15)(iv)Section 101A(7)Section 143(3)Section 32Section 37(1)Section 40Section 43BSection 44

facts and circumstances of the case and in law, ought to have held that learned AO erred in levying interest under section 234C of the Act of Rs 1,05,295 instead of Rs 11,561 considered by the Appellant in the revised return of income dated 29 March

M/S Tata Aig General Insurance Co.Ltd., Mumbai vs. ACIT - 8(3)(1), Mumbai

ITA 1815/MUM/2023[2016-17]Status: DisposedITAT Mumbai30 Oct 2024AY 2016-17

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Madhur Agrawal, AdvocateFor Respondent: Shri Biswanath Das, CIT DR
Section 10(15)(iv)Section 101A(7)Section 143(3)Section 32Section 37(1)Section 40Section 43BSection 44

facts and circumstances of the case and in law, ought to have held that learned AO erred in levying interest under section 234C of the Act of Rs 1,05,295 instead of Rs 11,561 considered by the Appellant in the revised return of income dated 29 March

Deutsche India Pvt. Ltd.(Earlier Known As 'Dboi Global Services Pvt. Ltd.), Mumbai vs. ACIT-1(3)(1), Mumbai

In the result, the appeal by the assessee is partly allowed for 16

ITA 2522/MUM/2022[2017-18]Status: DisposedITAT Mumbai28 Oct 2024AY 2017-18

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Shri J.D. MistriFor Respondent: Ms. Neena Jeph (CIT-DR)
Section 143(3)Section 144C(13)Section 144C(5)Section 92CSection 92D

chargeable per modified return of income. Deutsche India Pvt Ltd The appellants pray that the AO be directed to compute interest under section 234C at Rs.41,58,357 as per the modified return of income and delete the excess interest charged. The Appellants crave leave to add to, alter, amend

Anglo Eastern Institutes Private Limited, Mumbai vs. ITO 9(1)(3), Mumbai

In the result, the appeal of the assessee is allowed

ITA 631/MUM/2024[2017-18]Status: DisposedITAT Mumbai24 Oct 2024AY 2017-18

Bench: Shri Amit Shukla & Smt. Renu Jauhrianglo Eastern Institutes V/S. Cit(A)/Nfac, बनाम Pvt. Ltd. Delhi Unit No. 102, Mezzaniene Floor, Leela Business Park, Marol, Andheri-Kurla Road, Andheri (E), Maharashtra-400059 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aahcca3508K Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Ninad PatadeFor Respondent: Shri Manoj Kumar Sinha
Section 234Section 234BSection 234CSection 250Section 270A(1)Section 270A(9)(a)Section 71

levy of interest under section 2340 of the Act The Ld. AO has erred in law and in fact, in levying interest under section 234C of the Act. 5. Ground No. 5-Penalty under section 270A(1) of the Act The Ld. AO erred in initiating penalty proceedings under section

Alstom Sa, France vs. Deputy Commissioner of Income Tax, Circle 1(1)(1), International Taxation, New Delhi, Delhi

In the result, the appeal is allowed for statistical purposes

ITA 1444/DEL/2023[2016-17]Status: DisposedITAT Delhi17 Oct 2024AY 2016-17

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 234Section 234C

granting the correct credit towards taxes deducted at source the Appellant against the actual income earned by it. 3. Erroneous Levy of interest under Section 234C 2 Alstom SA, France 3.1. The learned AO erred in levying interest under section 2348 of the Act, which is consequential to the impugned ... adjustments made in the assessment order. 4. Erroneous Levy of interest under Section 234C 4.1. The learned AO erred in levying interest under section 234C of the Act, which is consequential to the impugned adjustments made in the assessment order. Each of the above ground is independent and without prejudice

Templeton Income Trust Templeton Global Bond Fund, Mumbai vs. The Deputy Commissioner of Income Tax (International Taxation ), Circle 4(1)(2), Mumbai

The appeal of the assessee are allowed

ITA 2508/MUM/2024[2023-24]Status: DisposedITAT Mumbai07 Oct 2024AY 2023-24

Bench: Shri Prashant Maharishi, Am & Shri Sunil Kumar Singh, Jm A.Y.2023-24 Templeton Income Trust The Dcit, Templeton Global Bond Fund, (International Taxation), 300 Se, 2Nd Street Fort Circle 4(1)(2), 17Th Floor Lauderdale, Florida-33301 Vs. United States Of America Air India Building, Nariman Point, Mumbai-400021 (Appellant) (Respondent) Pan Aabtt 3867F Assessee By None Revenue By Shri Anil Sant Addl. Cit(Dr) 22Nd July, 2024 Date Of Hearing 07Th October, 2024 Date Of Pronouncement

Section 115JSection 143Section 154Section 194LSection 196DSection 234CSection 89Section 90Section 90ASection 91

learned AO], was dismissed. 2. Assessee is aggrieved with the above order and has raised solitary grievance against the liability to pay interest under section 234C of the act of Rs. 1,097,402/–. 3. Despite notice to the assessee appeared and therefore the issue is decided based ... such application was dismissed by an order dated 16 October 2023 itself holding that there is no error in raising the demand of interest under section 234C of the Act. Therefore, appeal was filed before the learned CIT – A. It was contested that on all the income of the assessee

Mcnally Sayaji Engineering Limited, Kolkata vs. DCIT, Circle - 1(1), Kolkata

In the result, both the appeals are dismissed

ITA 899/KOL/2018[2009-10]Status: DisposedITAT Kolkata03 Oct 2024AY 2009-10

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Year: 2009-10 & Assessment Year: 2013-14 Mcnally Sayaji Engineering Deputy Commissioner Of Limited, Income Tax, Circle 1(1), Ecospace, Campus 2B, 11F/12 Aayakar Bhavan, P-7, (Old Plot No. Aa Ii/Blk 3), Chowringhee Square, Vs New Town, Rajarhat, Kolkata - 700069 North 24 Paragans, Kolkata - 7000156 (Pan: Aaccs5491A) (Appellant) (Respondent) Present For: Appellant By : Shri Abhishek Sureka, Ar Respondent By : Shri Rakesh Kumar Das, Cit, Dr Shri Vineet Kumar, Addl. Cit, Sr. Dr Date Of Hearing : 08.07.2024 Date Of Pronouncement : 03.10.2024 O R D E R Per Rakesh Mishra: These Two Appeals Filed By The Assessee Are Against The Two Separate Orders Of The Ld. Commissioner Of Income Tax, Kolkata-I, Kolkata (Hereinafter Referred To As “The Ld. Cit”) Passed U/S 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) For Ays 2009-10 & 2013- 14, Dated 28.02.2018 & 13.03.2018 Respectively. Both The Appeals Were Heard Together & Are Being Disposed Of Vide This Common Order For The Sake Of Brevity & Convenience. Mcnally Sayaji Engineering Limited.: Ays: 2009-10 & 2013-14 2. The Grounds Of Appeal Raised By The Assessee Are Reproduced As Under:

For Appellant: Shri Abhishek Sureka, ARFor Respondent: Shri Rakesh Kumar Das, CIT, DR
Section 234CSection 250Section 37Section 40

duly deposited within the due date, the deduction of the royalty paid should have been allowed in the subsequent assessment year 2010-11. Interest under section 234C of the Income Tax Act, 1961 7) For that the Commissioner of Income Tax (Appeals) erred in upholding the levy of interest under

Mcnally Sayaji Engineering Limited, Kolkata vs. DCIT, Circle - 1(1), Kolkata

In the result, both the appeals are dismissed

ITA 1145/KOL/2018[2013-14]Status: DisposedITAT Kolkata03 Oct 2024AY 2013-14

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Year: 2009-10 & Assessment Year: 2013-14 Mcnally Sayaji Engineering Deputy Commissioner Of Limited, Income Tax, Circle 1(1), Ecospace, Campus 2B, 11F/12 Aayakar Bhavan, P-7, (Old Plot No. Aa Ii/Blk 3), Chowringhee Square, Vs New Town, Rajarhat, Kolkata - 700069 North 24 Paragans, Kolkata - 7000156 (Pan: Aaccs5491A) (Appellant) (Respondent) Present For: Appellant By : Shri Abhishek Sureka, Ar Respondent By : Shri Rakesh Kumar Das, Cit, Dr Shri Vineet Kumar, Addl. Cit, Sr. Dr Date Of Hearing : 08.07.2024 Date Of Pronouncement : 03.10.2024 O R D E R Per Rakesh Mishra: These Two Appeals Filed By The Assessee Are Against The Two Separate Orders Of The Ld. Commissioner Of Income Tax, Kolkata-I, Kolkata (Hereinafter Referred To As “The Ld. Cit”) Passed U/S 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) For Ays 2009-10 & 2013- 14, Dated 28.02.2018 & 13.03.2018 Respectively. Both The Appeals Were Heard Together & Are Being Disposed Of Vide This Common Order For The Sake Of Brevity & Convenience. Mcnally Sayaji Engineering Limited.: Ays: 2009-10 & 2013-14 2. The Grounds Of Appeal Raised By The Assessee Are Reproduced As Under:

For Appellant: Shri Abhishek Sureka, ARFor Respondent: Shri Rakesh Kumar Das, CIT, DR
Section 234CSection 250Section 37Section 40

duly deposited within the due date, the deduction of the royalty paid should have been allowed in the subsequent assessment year 2010-11. Interest under section 234C of the Income Tax Act, 1961 7) For that the Commissioner of Income Tax (Appeals) erred in upholding the levy of interest under

Rameshkumar Kanaiyalal Patel, Mehsana vs. The ITO, Ward-1, Mehsana

In the result, appeal of the assessee is allowed

ITA 208/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad19 Sept 2024AY 2017-18

Bench: Ms. Suchitra Kambleassessment Year: 2017-18

Section 129Section 142(1)Section 143(2)Section 143(3)Section 144Section 147Section 148Section 234ASection 234BSection 234C

234B of the Act. 2. The Ld. Assessing Officer & Ld. Commissioner Officer has erred in law as well as on facts in charging interest under Section 234C of the Act. 3. The notice under Section 143(2) has been issued on 08.11.2019 when the return has been filed

Tamilnadu Industrial Development Corporation Limited, Chennai vs. DCIT Corp Circle 3(1), Chennai

In the result, the appeal of the assessee is allowed

ITA 1036/CHNY/2024[2018-19]Status: DisposedITAT Chennai18 Sept 2024AY 2018-19

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1036/Chny/2024 िनधा"रणवष" / Assessment Year: 2018-19 M/S. Tamilnadu Industrial The Deputy Commissioner Of Development Corporation Limited, V. Income Tax, 19-A, Rukminilakshmipathy Road, Corporate Circle 3(1), Egmore, Chennai – 600 008. Chennai – 600 034. [Pan:Aaact-3409-P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. R. Vijayaraghavan, Advocate ""यथ"क"ओरसे/Respondent By : Shri. Clement Ramesh Kumar, Cit सुनवाईकीतारीख/Date Of Hearing : 23.07.2024 घोषणाकीतारीख/Date Of Pronouncement : 18.09.2024

For Appellant: Shri. R. Vijayaraghavan, AdvocateFor Respondent: Shri. Clement Ramesh Kumar, CIT
Section 143(3)Section 18Section 234CSection 28Section 43Section 43B

interest tax paid /payable is allowable in computing the taxable income. Further, as per the return of income filed, no interest under section 234C is payable as the returned income is only a "loss" and interest under section 234C cannot be increased or charged over and above the amount ... return of income, while completing the scrutiny assessment. Since no interest under section 234C is payable as per the return of income, the charging of interest u/s.234C as per the scrutiny order is not correct and requires to be deleted. 7. Aggrieved by the order of the A.O, the assessee

Miranda Tools Private Limited, Mumbai vs. DCIT-7(3)(2), Mumbai

In the result, both the appeals of the assessee are allowed

ITA 1599/MUM/2023[2014-15]Status: DisposedITAT Mumbai13 Sept 2024AY 2014-15

Bench: Shri Om Prakash Kant & Shri Sunil Kumar Singh

For Appellant: Shri Anuj KisnadwalaFor Respondent: Smt. Mahita Nair, Sr.DR
Section 14Section 143(3)Section 14A

Ld.AO. Thus, the appellant prays that the interest u/s. 234B of the Act be deleted. 3. Inappropriate levy of interest under section 234C of the Act On the facts and in the circumstances of the case and in law, the CIT(A) erred in affirming the levy of interest

Miranda Tools Private Limited, Mumbai vs. DCIT RG 7(3)(2), Mumbai

In the result, both the appeals of the assessee are allowed

ITA 1598/MUM/2023[2013-14]Status: DisposedITAT Mumbai13 Sept 2024AY 2013-14

Bench: Shri Om Prakash Kant & Shri Sunil Kumar Singh

For Appellant: Shri Anuj KisnadwalaFor Respondent: Smt. Mahita Nair, Sr.DR
Section 14Section 143(3)Section 14A

Ld.AO. Thus, the appellant prays that the interest u/s. 234B of the Act be deleted. 3. Inappropriate levy of interest under section 234C of the Act On the facts and in the circumstances of the case and in law, the CIT(A) erred in affirming the levy of interest

Red Hat India Pvt Ltd, Mumbai vs. Dy CIT Circle- 15 (3)(1), Mumbai

ITA 215/MUM/2020[2015-16]Status: DisposedITAT Mumbai09 Sept 2024AY 2015-16

Bench: Shri Gagan Goyal & Shri Raj Kumar Chauhanm/S. Red Hat India Pvt. Ltd., A-201, Supreme Business Park, Supreme City, Hiranandani Gardens, Powai, Mumbai – 400 076, Pan No. : Aabcr7091N. ….. Appellant

For Appellant: Shri Ajit Jain, Ms. Nikhila Bhalla and Archita Bhalla Ld. ARsFor Respondent: Shri Yogesh Kamat Ld. CIT-DR
Section 143(3)Section 144C(10)

interest of INR 29, 41,649/- has been charged as per the Assessment Order. The Assessee has also challenged the levying of interest under section 234C of the Act. As per the facts mentioned by the assessee, it had paid the advance tax due on the returned income

Shell Information Technologies International Bv, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation)-4(2)(1), Mumba

In the result, the assessee’s appeal is partly allowed

ITA 4711/MUM/2023[2021-22]Status: DisposedITAT Mumbai06 Sept 2024AY 2021-22

Bench: Ms. Kavitha Rajagopal & Smt. Renu Jauhrishell Information V/S. Dcit (International Tax)- Technology International बनाम 4(2)(1), Bv 17Th Floor, Room No. 1708, C/O. Bsr & Co. Llp, Air India Building, 2Nd Floor, Lodha Excelus, Nariman Point, Apollo Mills Compound, Mumbai-400021 N.M. Joshi Marg, Mahalakshmi, Mumbai-400011 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaics9091A Appellant/अपीलाथी .. Respondent/प्रतिवादी

For Appellant: Shri Madhur AgarwalFor Respondent: Smt. Shaileja Rai
Section 143(3)Section 144C(13)Section 144C(5)Section 153Section 2(24)Section 234ASection 234BSection 234C

Erred in levying interest under section 234B of the Act without appreciating the facts and circumstance of the case. Interest under section 234C of the Act 13. Erred in levying interest under section 234C of the Act without appreciating the facts and circumstance of the case. Incorrect amount of refund

Tata Education Trust, Mumbai vs. Deputy Commissioner of Income Tax Circle-26(1), Mumbai

In the result the appeal of the assessee bearing ITA No

ITA 2610/MUM/2024[2022-23]Status: DisposedITAT Mumbai03 Sept 2024AY 2022-23

Bench: Shri Anikesh Banerjee & Shrigirish Agrawal

For Appellant: Shri Sukhsagar Syal a/w Shri Atul TFor Respondent: ShriP.D. Chougule (Addl. CIT) SRDR
Section 12ASection 143(1)Section 234CSection 244ASection 245Section 250

amounting to Rs.43,83,265/-; an cess was calculated at 4% amounting to Rs.13,44,201/-. Credit for TDS was claimed, interest under section 234C was levied of Rs.6,28,875/- and a refund of Rs.78,02,260/- was determined and claimed. Whereas in the intimation under section ... surcharge at the rate of 15% increased to Rs.44,11,390/-; and cess @4% increased to Rs.13,52,826/-. Interest under section 234C also increased to Rs.6,36,952/- eventhough the returned income remained unchanged. The refund has been determined in impugned intimation U/s 143(1) of the Act amount

Iqvia Rds(India) Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bengaluru

In the result, both the appeals by the assessee are allowed for statistical purposes

ITA 1237/BANG/2024[2021-22]Status: DisposedITAT Bangalore22 Aug 2024AY 2021-22

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

For Appellant: Shri Sharath Rao, CAFor Respondent: Shri D.K. Mishra, CIT(DR)(ITAT), Bengaluru
Section 143(1)Section 234CSection 250Section 43BSection 93

Accordingly, claimed as per the provisions of section 43B of the Act. ITA Nos. 1236 & 1237/Bang/2024 Page 3 of 6 Erroneous computation of interest under section 234C 4 of the Act (Rs.64,433) 4.1 The CIT(A) erred in not adjudicating the ground raised for erroneous computation of interest under

Iqvia Rds(India) Private Limited(Successor of Cenduit India Services Private Limited), Bangalore vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Banglaore

In the result, both the appeals by the assessee are allowed for statistical purposes

ITA 1236/BANG/2024[2021-22]Status: DisposedITAT Bangalore22 Aug 2024AY 2021-22

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

For Appellant: Shri Sharath Rao, CAFor Respondent: Shri D.K. Mishra, CIT(DR)(ITAT), Bengaluru
Section 143(1)Section 234CSection 250Section 43BSection 93

Accordingly, claimed as per the provisions of section 43B of the Act. ITA Nos. 1236 & 1237/Bang/2024 Page 3 of 6 Erroneous computation of interest under section 234C 4 of the Act (Rs.64,433) 4.1 The CIT(A) erred in not adjudicating the ground raised for erroneous computation of interest under

Investcorp Real Estate Yield Fund, Bandra, Mumbai vs. ITO-23(1)(1), Mumbai

In the result, appeal of the assessee is dismissed

ITA 4638/MUM/2023[2015-16]Status: DisposedITAT Mumbai07 Aug 2024AY 2015-16

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Raj Kumar Chauhan, Hon’Ble

For Appellant: Shri Dhanesh Bafna a/w Ms. Chandani Shah & MsFor Respondent: Shri Akshay Tapadiya, D/R
Section 143(1)Section 160(1)(iv)Section 234BSection 234C

facts and in the circumstances of the case and in law, the JCIT(A) erred in not directing the AO to delete the interest under section 234C of the Income- tax Act, 1961 ('the Act') computed in the Intimation under section

Emerging Markets Index Non Lendable Fund, Mumbai vs. DCIT (International Taxation)-2(2)(1), Mumbai

In the result appeal of the assessee is partly allowed

ITA 4589/MUM/2023[2021-22]Status: DisposedITAT Mumbai05 Aug 2024AY 2021-22

Bench: Shri Prashant Maharishi, Am & Shrisandeep Singh Karhail, Jm A.Y.2021 – 22 Emerging Markets Index The Deputy Commissioner Of Non-Lendable Fund Income Tax (International C/O Ernst & Young Llp Taxation) – Circle –2 (2) (1) 17Th Floor 1722, 17T H Floor, Vs. The Ruby Air India Building, 29, Senapati Bapat Marg Nariman Point, Dadar (West) Mumbai – 21 Mumbai – 28 (Appellant) (Respondent) Pan Aaaae3262D Assessee By Shri Anish Thacker & Pranay Gandhi Revenue By Shri Anil Sant Additional Commissioner Of Income Tax Date Of Hearing 7 May 2024 Date Of Pronouncement 5 August 2024

Section 111ASection 115ASection 234ASection 234BSection 234CSection 270A

interest under section 234A, ground number 10 against the levy of interest under section 234B and ground number 11 on levy of interest under section 234C of the act. Ground number 12 is against initiation of penalty proceedings under section 270A of the act. Ground number one is general , ground