“interest u/s 234C”

InterestSection 234CSection 234C252 judgments

The decision most relied on for interest u/s 234C is DIT v. NGC Network Asia LLC (313 ITR 187), cited in 144 judgments on BharatTax.

Leading authorities on interest u/s 234C

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. Ranchi Club Ltd.

247 ITR 209 · 2001 · Supreme Court

citing judgments

Interest under sections 234A and 234B cannot be levied mechanically when there is a reasonable cause for delay in payment or response to notices.

Judgments citing interest u/s 234C

Adarsh Journal Pvt. Ltd., New Delhi vs. ITO Ward-1(3), New Delhi

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

ITA 8589/DEL/2019[2016-17]Status: DisposedITAT Delhi28 Jun 2023AY 2016-17

Bench: Shri Kul Bharat & Shri M. Balaganeshassessment Year: 2016-17 Adarsh Journal Pvt. Ltd., Vs Ito, D-28, South Extension Part-I, Ward-1(3), New Delhi. New Delhi. Pan: Aabca1336R

For Appellant: Dr. Rakesh Gupta, AdvocateFor Respondent: Shri Kanav Bali, Sr. DR

Section 143(3)

interest u/s 234B of the Act would be consequential in nature and does not require any specific adjudication. With regard to chargeability of interest u/s 234C of the Act, the law is well settled that the same shall be charged only on the returned income and not on the assessed

Piramal Capital & Housing Finance Limited (Formerly Known As Dewan Housing Finance Corporation Limited), Mumbai vs. Assistant Commissioner of Income-Tax Central Circle 5(4), Mumbai

In the result, appeal of the assessee is allowed to the extent indicated hereinabove

ITA 199/MUM/2023[2017-18]Status: DisposedITAT Mumbai12 Jun 2023AY 2017-18

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm Piramal Capital & Housing Finance Limited The Asst. Commissioner Of (Formerly Known As Dewan Income-Tax Housing Finance Corporation Room No. 1927, Limited) 19 Th Floor, 4Th Floor, Piramal Tower Vs. Air India Building, Ganpatrao Kadam Marg, Nariman Point, Delisle Road, Mumbai-400 021 S.O. Mumbai Mumbai-400 013 (Appellant) (Respondent) Pan No. Aaacd1977A

For Appellant: Mr. Ronak Doshi &For Respondent: Mr. K.C. Selvamani, CIT DR

Section 14Section 143(3)Section 14A

deleted. Piramal Capital & Housing Finance Limited; A.Y. 17-18 WITHOUT PREJUDICE TO GROUND NO. I, II AND III, GROUND NO. IX: LEVY OF INTEREST U/S 234C OF THE ACT: 1. On the facts and circumstances of the case and in law, the Id. AO erred in levying incorrect interest u/s ... have held that in view of first proviso to section 234C (1), no interest would be applicable. 3. The Appellant prays that the interest u/s 234C be deleted or appropriately reduced. WITHOUT PREJUDICE TO GROUND NO. I. II AND III, GROUND NO. X: NON-GRANTING OF CREDIT OF DIVIDEND DISTRIBUTION

Thomas Cook (India) Ltd, Mumbai vs. Dy CIT 1 (3)92), Mumbai

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

ITA 7807/MUM/2019[2015-16]Status: DisposedITAT Mumbai31 May 2023AY 2015-16

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2015-16 Thomas Cook (India) Ltd., Dy. Cit-1(3)(2), A Wing, 11Th Floor, Marathon Room No. 540, 5Th Floor, Vs. Futurex, N.M. Joshi Marg, Aayakar Bhavan, M.K. Lower Parel (East), Road, Mumbai-400013. Mumbai-400020. Pan No. Aaact 4050 C Appellant Respondent Assessee By : Mr. Ketan Ved Revenue By : Ms. Richa Gulati, Dr : Date Of Hearing 30/05/2023 : Date Of Pronouncement 31/05/2023 Order

For Appellant: Mr. Ketan VedFor Respondent: Ms. Richa Gulati, DR

Section 115Section 115JSection 14ASection 37(1)

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “E” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND MS. KAVITHA

Strides Arcolab Ltd, Navi Mumbai vs. DCIT Cir 15(3)(2), Mumbai

The appeal of the assessee is allowed

ITA 1903/MUM/2015[2010-11]Status: DisposedITAT Mumbai23 May 2023AY 2010-11

Bench: Amit Shukla () & Ms. Padmavathy S. ()

Section 10BSection 115JSection 143(3)Section 144CSection 14ASection 35Section 92C

1 ITA 1903/Mum/2015 M/s Strides Arcolab Limited IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “J”, MUMBAI BEFORE AMIT SHUKLA

Cms Securities Limited, Mumbai vs. National E-Assessment Centre-Delhi, Mumbai

In the result, the appeal of the assessee is dismissed

ITA 3018/MUM/2022[2018-2019]Status: DisposedITAT Mumbai28 Apr 2023AY 2018-2019

For Appellant: NoneFor Respondent: V.S. Mahajan

Section 143(2)Section 234Section 270ASection 274Section 37(1)

brought before us any contrary submission therefore, this ground of appeal of the assesse stand dismissed. 6. Ground No. 1.4 levying of interest u/s 234C is consequential, therefore, the same is not required any adjudication accordingly this ground of appeal of the assessee is also dismissed. 7. In the result

Bhushan Kumar Uppal, New Delhi vs. ACIT, Central Circle-29, New Delhi

In the result, appeal of the assessee is allowed

ITA 1986/DEL/2018[2015-16]Status: DisposedITAT Delhi24 Apr 2023AY 2015-16

Bench: Shri Kul Bharat & Shri M. Balaganeshshri Manish Uppal (Legal Heir Of Vs. Acit, Bhushan Kumar Uppal), Central Circle-29, N-55, Panchsheel Park, New New Delhi Delhi-110017 (Appellant) (Respondent) Pan: Aaapu3998D

For Appellant: Sh. Salil Agarwal, Sr. AdvFor Respondent: Sh. Mahir Agarwal, Adv

Section 132Section 132(4)Section 132ASection 132BSection 143(3)Section 154Section 234B

would be in consequential in nature with regard to chargeability of interest u/s 234B of the Act. With regard to chargeability of interest u/s 234C of the Act, the law is very settled that the same may be charged only on the returned income and not on the assessed income

Heg Ltd, Mandideep vs. DCIT Central Circle-31, New Delhi

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

ITA 13/DEL/2021[2011-12]Status: DisposedITAT Delhi12 Apr 2023AY 2011-12

Section 14ASection 220(2)Section 234CSection 244A

allowed. 5. Ground No.4 raised by the assessee for AY 2010-11 is with regard to chargeability to interest u/s 234C of the Act. The law is very well settled that interest u/s 234C of the Act could be done only on the returned income and not on the assessed

Heg Ltd., Raisen vs. DCIT, Central Circle- 31, New Delhi

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

ITA 5907/DEL/2019[2010-11]Status: DisposedITAT Delhi12 Apr 2023AY 2010-11

Section 14ASection 220(2)Section 234CSection 244A

Bhilai Jaypee Cement Ltd., Durg vs. Dy. Commissioner of Income Tax-1(1), Durg

In the result, appeal of the assessee is allowed for statistical purposes in terms of our aforesaid observations

ITA 85/RPR/2021[2012-13]Status: DisposedITAT Raipur28 Mar 2023AY 2012-13

Bench: Shri Ravish Sood & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No. 85/Rpr/2021 "नधा"रण वष" / Assessment Year : 2012-13 Bhilai Jaypee Cement Ltd. 14-B, F- Pocket, Maroda Sector, Bhilai Township, Bhilai, Dist. Durg (C.G.)-490 006 Pan : Aadcb1675Q

For Appellant: Shri Rakesh Dhody, CAFor Respondent: Shri Piyush Tripathi, Sr. DR

Section 143(2)Section 143(3)Section 234CSection 36(1)(va)Section 43B

payments was allowed. 4) That CIT(A) erred in not adjudicating following additional legal ground of appeal taken before him because interest u/s 234C was charged by the Assessing Officer in spite of assessing total loss of Rs.1,39,12,41,691/- and TDS/TCS of Rs.13,08,590/- & tax payment ... Rs.33,520/- appearing in Form 26AS for the A.Y. 2012/13:- "That Assessing Officer erred in charging interest u/s. 234C of Rs. 13,00,307/-". 5) The appellant reserves the right to add, amend, or alter any ground or grounds of appeal at the time of hearing.” 2. Succinctly stated

Navodia Times Private Limited, Jalandhar vs. Deputy Commissioner of Income Tax Circle-1, Jalandhar

In the result, the appeal of the assessee bearing ITA 192/Asr/2022 is

ITA 192/ASR/2022[2018-19]Status: DisposedITAT Amritsar31 Jan 2023AY 2018-19

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 139(1)Section 143Section 143(1)Section 234CSection 250oSection 36

Learned Commissioner of Income tax (Appeals) has erred in not appreciating the submissions made regarding the wrong levy of interest u/s 234C. The submission made has not even been considered. In any case, interest u/s 234C is based on returned income only.” 3. Brief fact of the case is that

M/S. Mercator Ltd, Mumbai vs. The Dy CIT 5(2), Mumbai

In the result, the appeal filed by the revenue and CO by the asssessee are dismissed and the asseessee appeal is allowed for statistical purposes

ITA 7278/MUM/2017[2010-11]Status: DisposedITAT Mumbai21 Dec 2022AY 2010-11

Bench: Shri Baskaran Br & Shri Pavan Kumar Gadaleita No. 7278/Mum/2017 (A.Y: 2010-11) & Co No. 21/Mum/2019 (2010-11) (Arising Out Of Ita No. 29/Mum/2018) Mercator Ltd Vs. Dcit 3Rd Floor, Mittal Tower- Range 5(2) B Wing, Nariman Point Aayakar Bhavan, Mk Mumbai- 400021. Road, Mumbai-400020. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacm5007A Appellant .. Respondent Dy. Cit Vs. Mercator Lines Ltd Range 5(2)(2), Rno.571 3Rd Floor, Mittal Tower- Aayakar Bhavan, Mk B Wing, Nariman Point Road, Mumbai – 400 021. Mumbai - 400020. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacm5007A Appellant .. Respondent Assessee By : Mr.Nikhil Tiwari.Ar Revenue By : Mr.Krishnakumarmishra.Dr Date Of Hearing 30.11.2022 Date Of Pronouncement 22.12.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: 29/Mum/2018 & Co No. 21/Mum/2019 M/S. Mercator Ltd, Mumbai. The Cross Appeal Is Filed By The Assessee & The Revenue Against The Order Of The Commissioner Of Income Tax (Appeals) (Cit(A))-57, Mumbai Passed U/S 250 Of The Act & The Assessee Has Filed The Cross Objection(Co) In The Revenue Appeal.

For Appellant: Mr.Nikhil Tiwari.ARFor Respondent: Mr.KrishnaKumarMishra.DR

Section 143(3)Section 14ASection 250

corporate tax additions on disallowance u/s 14A of the Act and ground no 27 and 28 are in respect of levy of interest u/s 234C and 234D of the Act and ground of appeal no 29 with regard to initiating penalty u/s 274 r.w.s

Ask Investment Managers Limited, Mumbai vs. Dy Commissioner of Income Tax, 6(1)(2), Mumbai

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

ITA 1115/MUM/2022[2019-20]Status: DisposedITAT Mumbai13 Dec 2022AY 2019-20

Bench: Shri Amarjit Singh & Shri Rahul Chaudharyask Investment Vs. Dcit-6(1)(2) Managers Limited Aayakar Bhavan, Birla Aurora, 16 Level, M.K. Road, Office Floor 9, Dr. Annie Mumbai - 400020 Besant Road, Worli, Mumbai – 400030 स्थायी लेखा सं./जीआइआर सं./ Pan/Gir No: Aafca2302P Appellant .. Respondent Appellant By : J.D. Mistri & Shreyam Shah Respondent By : Mehul Jain

For Appellant: J.D. Mistri &For Respondent: Mehul Jain

Section 234Section 234BSection 234CSection 23B

supported the order lower authorities. 5. Heard both the sides and perused the material on record. The CPC, Banglore has charged excess interest u/s 234C of the Act at Rs.8,51,047/- as referred supra in this order. The assessee has submitted that it is engaged in the business Portfolio ... interest u/s 234B of Rs.2,49,643/- is consequential, since, we have already allowed ground of appeal of the assessee on charging excess interest u/s 234C of the Act, therefore, this ground pertaining to charging interest u/s 234B become infructuous and not required any adjudication, therefore, the same stand dismissed

Tangar Exports LLP, Ranipet vs. ADIT, CPC, Bangalore / ACIT, Vellore

In the result, appeal filed by the assessee is allowed

ITA 666/CHNY/2022[2018-2019]Status: DisposedITAT Chennai07 Dec 2022AY 2018-2019

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita No.: 666/Chny/2022 िनधा"रण वष" / Assessment Year: 2018-19 Tangar Exports Llp, Adit, No. 3 (Old No. 2A/4), Railway V. Cpc, Bengaluru, Station Road, Acit, Vellore. Ranipet – 632 401. [Pan: Aaift-3781-B] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. A. Mahesh, Ca ""यथ" क" ओर से/Respondent By : Shri. D. Hema Bhupal, Jcit सुनवाई क" तारीख/Date Of Hearing : 30.11.2022 घोषणा क" तारीख/Date Of Pronouncement : 07.12.2022 आदेश /O R D E R

For Appellant: Shri. A. Mahesh, CAFor Respondent: Shri. D. Hema Bhupal, JCIT

Section 143Section 143(1)Section 143(1)(a)Section 234BSection 234CSection 80J

u/s 80JJAA, Rs.176543, :-2-: ITA. No:666/Chny/2022 ii) Consequent levy of tax & cess; iii) Levy of interest u/s 234B and iv) Computation of interest u/s 234C for 2018-19 a/y on the following grounds: 1. The CIT(A) erred in not deciding the illegality of the 'adjustment' (denial of deduction ... Rs.176543 u/s BOJJAA be allowed; ii) Consequent Levy of tax, cess etc. be deleted; iii) Interest levied u/s 234B be deleted & iv) correct interest u/s 234C, as in the return, be computed and justice rendered.” The brief facts of the case are that the assessee has filed 3. return

Arya Samaj, Bangalore vs. Income Tax Officer, Ward-1, Bangalore

In the result, appeal by the Assessee is allowed

ITA 984/BANG/2022[2018-19]Status: DisposedITAT Bangalore25 Nov 2022AY 2018-19

Bench: Shri N. V. Vasudevanassessment Year : 2018-19 M/S. Arya Samaj, Vs. Ito (Exemptions), Ward - 1, No.804/15, Swamy Shraddhanand Bhavan, Bengaluru. Vishveshvarapuram, Bengaluru – 560 004. Pan : Aacta 0479 K Assessee Respondent Assessee By : Shri. Sudheendra B. R, Advocate Revenue By : Shri. Ganesh R Ghale, Standing Counsel Date Of Hearing : 24.11.2022 Date Of Pronouncement : 25.11.2022 O R D E R

For Appellant: Shri. Sudheendra B. R, AdvocateFor Respondent: Shri. Ganesh R Ghale, Standing Counsel

Section 11Section 11(1)(d)Section 12ASection 12A(2)Section 143(1)Section 234ASection 234BSection 234CSection 234F

return of income. The demand also includes following interests: Interest u/s 234A Rs. 48,377/- Interest u/s 234B Rs. 1,24,398/- Interest u/s 234C Rs. 34,901/- Interest u/s 234F Rs. 10,000/- 4. The following variations in the income computed are noticed in the intimation: Particulars

Spe India Films Holding Llc, Mumbai vs. ACIT (Intl Tax) -4(2) (2), Mumbai

In the result ground no-2 raised by the assessee- is fully allowed

ITA 457/MUM/2022[2018-19]Status: DisposedITAT Mumbai21 Sept 2022AY 2018-19

Bench: Shri Amit Shukla & Shri Gagan Goyalspe India Films Holding Llc C/O, Deloitte Haskins & Sells Llp One International Centre, Tower No.3, 27Th Floor-32Nd Floor, Senapati Bapat Marg, Elphinstone Road (W), Mumbai-400013. Pan: Aaocs1827L ...... Appellant Vs. Acit (International Taxation)-4(2)(2) 16Th Floor, Air India Building, Narimaon Point, Mumbai-400021. ..... Respondent Appellant By : Sh. P.J. Pardiwala/Paras Savla Respondent By : Sh. A.K. Keshari Date Of Hearing : 27/06/2022 Date Of Pronouncement : 21/09/2022 Order Per Gagan Goyal, A.M: This Appeal By The Assessee Is Directed Against The Order Of Dispute Resolution Panel-2, Mumbai [Hereinafter Referred To As [‘Drp’] Dated 06.01.2022 For The Assessment Year (Ay) 2018-19. The Assessee Has Raised The Following Grounds Of Appeal: “The Appellant, Objects To The Order Dated 19 January 2022 Passed Under Section 143(3) R.W.S 144C(13) Of The Income Tax Act, 1961 (Act) Passed By The Learned Assistant Commissioner Of Income-Tax (International Taxation) - 4(2)(2), Mumbai

For Appellant: Sh. P.j. Pardiwala/Paras SavlaFor Respondent: Sh. A.K. Keshari

Section 143(3)Section 234BSection 234CSection 270ASection 9(1)(vi)

234B is consequential in nature and its quantification depends on the outcome of directions given supra against ground no-1. As far as interest u/s 234C is concerned that can’t be consequential to any addition made by AO, and the same is based on the returned figure hence ... same is liable to be deleted. AO is directed to delete the interest u/s 234C and recompute the interest u/s 234B keeping in view our findings in Ground 1, 2 and 3. In the result Ground raised by the assessee is partly allowed. 11. In the result, appeal filed

Duck Creek Technologies India LLP, Mumbai vs. ACIT- Circle 26 (1), Mumbai

In the result, the appeal is allowed

ITA 1898/MUM/2021[2018-19]Status: DisposedITAT Mumbai26 Aug 2022AY 2018-19

Section 139(1)Section 143(1)Section 234CSection 36(1)(va)Section 43BSection 44A

before the due date of filing of return of income under section 139(1) of the Act Levy of incorrect interest u/s 234C of the Act 6. The Learned CIT(A) has erred in upholding CPC's contention of levying interest u/s 234C on assessed income as against returned income

Hamilton Industries Pvt. Ltd., Mumbai vs. ITO -WD 7(1)(1), Mumbai

In the result, appeal filed by the assessee is allowed

ITA 218/MUM/2022[2018-19]Status: DisposedITAT Mumbai10 Aug 2022AY 2018-19

Bench: Shri Aby T Varkey & Shri Gagan Goyalm/S Hamilton Industries Pvt. Ltd. Unit No. 8 & 9, Ground Floor, Kakad, Chamber, 132, Dr. Annie Besant Road, Worli, Mumbai-400018. Pan: Aaach0375E ...... Appellant Vs. Ito, Ward 7(1)(1), Aayakar Bhavan, Mumbai-400020. ..... Respondent Appellant By : Sh. Piyush Chhajed, C.A Respondent By : Sh. Prasoon Kabra Date Of Hearing : 18/05/2022 Date Of Pronouncement : 10/08/2022 Order Per Gagan Goyal, A.M:

For Appellant: Sh. Piyush Chhajed, C.AFor Respondent: Sh. Prasoon Kabra

Section 139(1)Section 143(1)Section 143(1)(a)Section 154Section 208Section 234CSection 250Section 44A

calculations of tax payable, interest, figures of income returned and other figures embodied in the return were accepted by the CPC Bangalore. Except, interest u/s 234C was enhanced by Rs 12, 31,304/- by CPC, Bangalore. 4. In response to the said intimation the assessee had filed an application ... ITAT Jaipur bench in the case of M/s GIE Jewels (ITA No. 794/JP/2017), decided in the favour of charging interest u/s 234C of the Act. 6 ITA No. 218 Mum 2022-M/s Hamilton Industries Pvt. Ltd. 8. We have analysed circular no.13, cases decided in favour of revenue (supra

M/S Delhi International Airport Private Limited, Bangalore vs. Joint Commissioner of Income Tax(OSD) Central Circle-2(2), Bangalore

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

ITA 127/BANG/2022[2016-17]Status: DisposedITAT Bangalore09 Jun 2022AY 2016-17

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Appellant: Sri.Sunil Jain, CAFor Respondent: Sri.Priyadarshi Mishra, Addl.CIT -DR

Section 115JSection 143(3)Section 154Section 234CSection 244ASection 250

u/s 115JB of the Act. The tax payable on income computed u/s. 115JB were worked out at Rs.127,93,98,538/- (including interest U/s 234C of Rs.75,01,446) as against the amount of prepaid taxes of 3 ITA No.127/Bang/2022. M/s.Delhi International Airport Limited. Rs.128,66,76,042/- comprising ... 115JB of IT Act. The amount of tax payable on income computed u/s. 115JB were worked out at Rs.127,70,61,709/- (including interest U/s 234C of Rs.51,64,617/-) as against the amount of prepaid taxes of Rs.134,43,75,586/- comprising of TDS of Rs.114

Tesco Bangalore Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-7(1)(1), Bangalore

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

ITA 602/BANG/2016[2011-12]Status: PendingITAT Bangalore23 May 2022AY 2011-12

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranit(Tp)A No.602/Bang/2016 Assessment Year : 2011-12 M/S. Tesco Bengaluru Private Limited, Dcit, Vs. (Earlier Known As Tesco Hindustan Service Circle – 7(1)(1), Centre Private Limited), Bengaluru. No.81 & 82, Tesco H S C, Epip Area, White Field, Bengaluru-560 066. Pan : Aabct 8915 B Appellant Respondent Assessee By : Shri. T. Suryanarayana, Advocate Revenue By : Shri. Sumer Singh Meena, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 22.02.2022 Date Of Pronouncement : 23.05.2022 O R D E R Per B. R. Baskaran:

For Appellant: Shri. T. Suryanarayana, AdvocateFor Respondent: Shri. Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru

Section 10ASection 143(3)Section 234BSection 234C

short credit of TDS (c) arithmetical error in computing total income (d) disallowance of miscellaneous expenses relating to Penalty (e) Levy of interest u/s 234C Accordingly, all these grounds are dismissed as Not Pressed. Ground No.27 relates to levy of interest u/s 234B and 234D. Since it is consequential

M/S. Gia India Laboratories Pvt.Ltd, Mumbai vs. The DCIT, Bangalore

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

ITA 234/MUM/2022[2018-19]Status: DisposedITAT Mumbai25 Apr 2022AY 2018-19

Bench: Shri Vikas Awasthy & Shri Amarjit Singhgia India Laboratory Pvt. Vs. The Dcit, Cpc, Ltd., 10Th Floor, Trade Bangalore, Centre, Bandra Kurla 560500 Complex Bandra (E) Mumbai – 400 098 "थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaccg9457G Appellant .. Respondent

For Appellant: Shri Niraj ShethFor Respondent: Shri Hoshang B. Irani

Section 139(1)Section 143(1)Section 234CSection 36(1)(va)Section 43B

directed to grant full credit for tax deducted at source and to re-compute the Appellant's tax liability accordingly. 3 : 0 Re.: Interest u/s. 234C of the Income-tax Act, 1961 has been levied in excess by Rs. 50,012/-: 3 : 1 The Commissioner of Income-tax (Appeals ... assessee is allowed for statistical purposes. 5 ITA No. 234/Mum/2022 A.Y.2018-19 GIA India Laboratory Pvt. Ltd. Vs. The DCIT, CPC, Bangalore Ground 3: Interest u/s 234C of the Income Tax Act has been levied in excess by Rs.50,012/: 8. The ld. Counsel has submitted that CPC Bangalore has incorrectly