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“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
21
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

Sms Group Gmbh, Delhi vs. ACIT.Circle-3(1)(2), New Delhi

In the result, the appeal of the assessee in ITA No

ITA 377/DEL/2025[2022-23]Status: DisposedITAT Delhi24 Dec 2025AY 2022-23

Bench: Shri M. Balaganesh & Shri Vimal Kumar

For Appellant: Shri Percy Pardiwala, Sr. AdvFor Respondent: Shri M. S. Nethrapal, CIT DR
Section 143(3)Section 144C(5)

u/s 234B and 234C of the Act. The chargeability of interest u/s 234B of the Act is consequential in nature. With regard to interest u/s 234C of the Act, the law is very well settled that same shall be charged only on the returned income and not on the assessed ... directed accordingly. The interest u/s 234B of the Act is consequential in nature. With regard to interest u/s 234C of the Act, the law is very well settled that the same shall be charged only on the returned income and not on the assessed income. The Ground No. 5 raised

Sms Group Gmbh, New Delhi vs. ACIT, Circle 3(1)(2), International Txation, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 993/DEL/2023[2020-21]Status: DisposedITAT Delhi24 Dec 2025AY 2020-21

Bench: Shri M. Balaganesh & Shri Vimal Kumar

For Appellant: Shri Percy Pardiwala, Sr. AdvFor Respondent: Shri M. S. Nethrapal, CIT DR
Section 143(3)Section 144C(5)

u/s 234B and 234C of the Act. The chargeability of interest u/s 234B of the Act is consequential in nature. With regard to interest u/s 234C of the Act, the law is very well settled that same shall be charged only on the returned income and not on the assessed ... directed accordingly. The interest u/s 234B of the Act is consequential in nature. With regard to interest u/s 234C of the Act, the law is very well settled that the same shall be charged only on the returned income and not on the assessed income. The Ground No. 5 raised

Sms Group Gmbh, New Delhi vs. ACIT Circle - 3(1)(2) Intl. Taxation, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 3297/DEL/2023[2021-22]Status: DisposedITAT Delhi24 Dec 2025AY 2021-22

Bench: Shri M. Balaganesh & Shri Vimal Kumar

For Appellant: Shri Percy Pardiwala, Sr. AdvFor Respondent: Shri M. S. Nethrapal, CIT DR
Section 143(3)Section 144C(5)

u/s 234B and 234C of the Act. The chargeability of interest u/s 234B of the Act is consequential in nature. With regard to interest u/s 234C of the Act, the law is very well settled that same shall be charged only on the returned income and not on the assessed ... directed accordingly. The interest u/s 234B of the Act is consequential in nature. With regard to interest u/s 234C of the Act, the law is very well settled that the same shall be charged only on the returned income and not on the assessed income. The Ground No. 5 raised

Sms Group Gmbh, New Delhi vs. ACIT, Circle-3(1)(2) Int. Taxation, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 1592/DEL/2022[2018-19]Status: DisposedITAT Delhi24 Dec 2025AY 2018-19

Bench: Shri M. Balaganesh & Shri Vimal Kumar

For Appellant: Shri Percy Pardiwala, Sr. AdvFor Respondent: Shri M. S. Nethrapal, CIT DR
Section 143(3)Section 144C(5)

u/s 234B and 234C of the Act. The chargeability of interest u/s 234B of the Act is consequential in nature. With regard to interest u/s 234C of the Act, the law is very well settled that same shall be charged only on the returned income and not on the assessed ... directed accordingly. The interest u/s 234B of the Act is consequential in nature. With regard to interest u/s 234C of the Act, the law is very well settled that the same shall be charged only on the returned income and not on the assessed income. The Ground No. 5 raised

Sms Group Gmbh, New Delhi vs. ACIT, Circle-3(1)(2), Int. Taxation, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 1591/DEL/2022[2017-18]Status: DisposedITAT Delhi24 Dec 2025AY 2017-18

Bench: Shri M. Balaganesh & Shri Vimal Kumar

For Appellant: Shri Percy Pardiwala, Sr. AdvFor Respondent: Shri M. S. Nethrapal, CIT DR
Section 143(3)Section 144C(5)

u/s 234B and 234C of the Act. The chargeability of interest u/s 234B of the Act is consequential in nature. With regard to interest u/s 234C of the Act, the law is very well settled that same shall be charged only on the returned income and not on the assessed ... directed accordingly. The interest u/s 234B of the Act is consequential in nature. With regard to interest u/s 234C of the Act, the law is very well settled that the same shall be charged only on the returned income and not on the assessed income. The Ground No. 5 raised

Patel Sew Joint Venture, Telangana vs. DCIT., Circle-6(1), Hyderabad

In the result, the cross-objection filed by the assessee is dismissed

ITA 884/HYD/2025[2019-20]Status: DisposedITAT Hyderabad19 Dec 2025AY 2019-20
Section 139(5)Section 143(1)Section 234ASection 234BSection 234CSection 80Section 801A(4)

u/s 234B of the Act. 5) On the facts and circumstances of the case and in law, the Learned A.O. erred in charging interest u/s 234C of the Act.” 3. The brief facts of the case are that, the assessee is a Joint Venture between M/s. Patel Engineering

ACIT., Circle-6(1), Hyderabad vs. Patel Sew Jointventure, Hyderabad

In the result, the cross-objection filed by the assessee is dismissed

ITA 742/HYD/2025[2023-24]Status: DisposedITAT Hyderabad19 Dec 2025AY 2023-24
Section 139(5)Section 143(1)Section 234ASection 234BSection 234CSection 80Section 801A(4)

u/s 234B of the Act. 5) On the facts and circumstances of the case and in law, the Learned A.O. erred in charging interest u/s 234C of the Act.” 3. The brief facts of the case are that, the assessee is a Joint Venture between M/s. Patel Engineering

Qualcomm Incorporated, San Diego, California vs. Deputy Commissioner of Income Tax Circle 3(1)(1), New Delhi

In the result, the appeal of the assessee for AY 2022-23 is allowed for 14

ITA 2087/DEL/2025[2022-23]Status: DisposedITAT Delhi10 Dec 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri M. Balaganesh

For Appellant: Shri Nishant Thakkar, AdvFor Respondent: Shri M. S. Nethrapal, CIT DR
Section 115ASection 143(3)Section 144C(5)Section 153Section 234BSection 270ASection 9

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “D”: NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI M. BALAGANESH, ACCOUNTANT

Qualcomm Incorporated, San Diego, California vs. Deputy Commissioner of Income Tax Circle 3(1)(1), New Delhi

In the result, the appeal of the assessee for AY 2022-23 is allowed for 14

ITA 2086/DEL/2025[2018-19]Status: DisposedITAT Delhi10 Dec 2025AY 2018-19

Bench: Shri Vikas Awasthy & Shri M. Balaganesh

For Appellant: Shri Nishant Thakkar, AdvFor Respondent: Shri M. S. Nethrapal, CIT DR
Section 115ASection 143(3)Section 144C(5)Section 153Section 234BSection 270ASection 9

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “D”: NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI M. BALAGANESH, ACCOUNTANT

Khadakala Seva Sahkari Manadli Ltd., Rajkot (Amreli) vs. The ITO Ward - 3 (1) (4) Amreli, Amreli

In the result, appeal filed by the assessee is dismissed, as indicated above

ITA 199/RJT/2025[2018-19]Status: DisposedITAT Rajkot28 Nov 2025AY 2018-19

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./ Ita No.199/Rjt/2025 "नधा"रण वष"/Assessment Year :2018-19 Khadakala Seva Sahkari Mandali Income Tax Officer Ltd. Ward 3(1)(4), Amreli बनाम/ Savarkundla, Amreli, 364515 Gujarat - 365650 Vs [C/O. D. R. Adhia Om Shri Padamlaya, Near Trikamrayji Haweli, 16- Jagnath Plot, Dr. Yagnik Road, Opp. Imperial Hotel, Rajkot, Gujarat 360001] "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabak3647B (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Written Submission राज"व क" ओर से/Revenue By : Shri Dheeraj Kumr Gupta, Ld. Sr-Dr सुनवाई क" तार"ख /Date Of Hearing : 10/09/2025 घोषणा क" तार"ख /Date Of Pronouncement : 28/11/2025 आदेश/Order Per, Dr. Arjun Lal Saini, A.M:

For Appellant: Written SubmissionFor Respondent: Shri Dheeraj Kumr Gupta, Ld. Sr-DR
Section 143(1)Section 234ASection 234BSection 234CSection 250Section 80P

erred in confirming the same. The same needs cancellation. 5. The Ld. A.O. erred in law as well as on facts in charging interest U/s 234C of Rs. 5,434 /-. The Ld CIT(A) has also erred in confirming the same. The same needs cancellation 6. The Ld. A.O. erred

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

In the result, both appeals of the Assessee are allowed for statistical purposes

ITA 2707/PUN/2024[2022-23]Status: DisposedITAT Pune26 Nov 2025AY 2022-23

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

levy of penalty u/s. 234C of the Act. 4. Learned counsel for the assessee referring to the grounds of appeal submitted that interest u/s. 234C can be levied only on the returned income and not on the assessed income and that on deletion of the erroneous addition made, the interest ... income at Rs. 4,17,17,06,640/-. Further, CPC also levied 3 ITA.Nos.2706 & 2707/PUN/2024 (BNY Mellon International Operations (India) Pvt. Ltd.) interest u/s. 234C of the Act of Rs. 1,11,43,464/- as against the interest calculated by the assessee u/s. 234C

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

u/s.234C of the Act, Ld.CIT(A) rejected the same observing as follows:- “The Appellant has raised one additional ground regarding the charging of Interest u/s 234C. I find that in the computation of Total Income and Tax thereon as per the Assessment u/s 143(3), the Interest u/s 234C

Rockwell Automation India Private Limited, Delhi vs. DCIT Circle-19(1), Delhi

Appeal is partly allowed for statistical purposes

ITA 3861/DEL/2024[2020-21]Status: DisposedITAT Delhi17 Nov 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalrockwell Automation India Deputy Commissioner Of Private Limited, Income Tax, Circle-19(1), Registered Address: 131, Vs. Delhi. Functional Industrial Are, Patparganj, Delhi-110092 Communication Address: 131, Functional Industrial Area, Patparganj, New Delhi. Pan-Aaccr3791A (Appellant) (Respondent) Assessee By Shri Ajit Jain, Ar Department By Shri Dharm Veer Singh, Cit-Dr Date Of Hearing 19.08.2025 Date Of Pronouncement 17.11.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Final Assessment Order Passed U/S 143(3) R.W.S 144C (13) Read With Section 144B Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) Dated 30.07.2024 For Assessment Year 2020-21. 2. Brief Facts Of The Case Ae That The Assessee Is A Company Engaged In The Business Of Manufacturing / Assembling Of Automation & Industrial Control Products / Systems. The Case Was Selected For Scrutiny & A Reference Was Made To The Tpo Due With Transactions With Ae’S. The Return Of Income Was Filed On Rockwell Automation India Private Limited Vs. Dcit 15.02.2021 Declaring Total Income At Rs.97,08,46,360/-. The Tpo Vide Its Order Dated 28.07.2023 Passed U/S 92Ca(3) Of The Act Has Proposed Adjustments Totaling To Rs. 26,12,44,668/-. Thereafter, The Ao Has Passed The Draft Assessment Order U/S 144C(1) Of The Act Dated 27.09.2023 Wherein The Ao Has Proposed The Additions Towards The Tp Adjustment As Per Tpo’S Order & Proposed To Assess The Total Income Of The Assessee At Rs.19,88,57,458/- & Further Proposed To Disallow Relief Claimed U/S 90/90A At Rs.1,04,60,287/-. Against The Draft Assessment Order, The Assessee Filed Objections Before The Drp.

Section 143(3)Section 144BSection 144C(1)Section 144C(10)Section 144C(13)Section 144C(8)Section 90Section 90ASection 92C

interest u/s 234A and 234B of the Act on the income which is finally computed after giving effect to this order. The interest u/s 234C would be charged on the income declared by the assessee in the return of income filed. With these directions, these grounds of appeal are partly

The Warangal District Cooperative Central Bank Limited, Hanamkonda vs. DCIT, Circle-3(1), Hyderabad

ITA 364/HYD/2023[2021-22]Status: DisposedITAT Hyderabad14 Nov 2025AY 2021-22

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.364/Hyd/2023 ("नधा"रण वष"/Assessment Year:2021-22) The Warangal District Vs. Deputy Commissioner Of Cooperative Central Bank Income Tax, Limited, Hanamkonda, Circle-3(1), Warangal. Hyderabad. Pan: Aabtt3137G (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Sri S. Rama Rao, Advocate राज" व "वारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई क" तार"ख/Date Of 11/11/2025 Hearing: घोषणा क" तार"ख/Date Of 14/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M:

For Appellant: Sri S. Rama Rao, AdvocateFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 115BSection 143(1)Section 143(1)(a)Section 234CSection 36(1)(va)

been made by the CPС. 8. The learned Commissioner of Income-Tax (Appeals) erred in confirming the action of the CPC in charging interest u/s 234C of Rs.36,202/-. 3 The Warangal District Cooperative Central Bank Limited vs. DCIT 9. Any other ground that may be urged at the time

Nirma Credit & Capital Pvt. Ltd., Ahmedabad vs. The ITO, Ward-3(1)(1), Ahmedabad

In the result, the appeal filed by the assesse is allowed for statistical purpose

ITA 101/AHD/2025[2023-24]Status: DisposedITAT Ahmedabad13 Nov 2025AY 2023-24

Bench: Ld. Cit (A) Was Against Charging Interest U/S 234C Of I.T. Act For Rs.7,93,284/-On Capital Gain Arose On 30-03-2023. Hence Interest U/S 234 C Cannot Be Charged Up To 15-03-2023. 3) Your Appellant Reserves The Right To Add, Alter, Amend All Or Any Of The Above Grounds Of Appeal As May Be Advised From Time To Time.

Section 115JSection 143(1)Section 234Section 234BSection 234CSection 250(4)

Challans are enclosed. The ground of the appellant before Ld. CIT (A) was against charging interest u/s 234C of I.T. Act for Rs.7,93,284/-on capital gain arose on 30-03-2023. Hence interest u/s 234 C cannot be charged up to 15-03-2023. 3) Your appellant reserves ... u/s. 115JB as Rs.10,41,48,658/-. Interest u/s. 234B of the Act of Rs.5,50,756/- charged instead of Rs.4,75,631/-. Interest u/s. 234C of the Act was wrongly charged at Rs. 7,93,284 and demand Tax of Rs. 8,32,970/-. 3. Aggrieved against the intimation

Kanatalaw Seva Sahakari Mandali Ltd., Rajkot (Amreli) vs. The ITO Ward - 3 (1) (4) Amreli, Amreli

ITA 201/RJT/2025[2019-20]Status: DisposedITAT Rajkot06 Nov 2025AY 2019-20

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./ Ita Nos.200 & 201/Rjt/2025 "नधा"रण वष"/Assessment Years :2018-19 & 2019-20 Kanatalaw Seva Sahkari Mandli Income Tax Officer Limited Ward 3(1)(4), Amreli बनाम/ Kanatalaw, Savarkundla, Vs Amreli - 364515 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aakfk8797L (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Written Submission राज"व क" ओर से/Revenue By : Shri Dheeraj Kumr Gupta, Ld. Sr-Dr सुनवाई क" तार"ख /Date Of Hearing : 10/09/2025 घोषणा क" तार"ख /Date Of Pronouncement : 06/11/2025 आदेश/Order Per, Dr. Arjun Lal Saini, A.M

For Appellant: Written SubmissionFor Respondent: Shri Dheeraj Kumr Gupta, Ld. Sr-DR
Section 143(1)Section 234ASection 234BSection 234CSection 250Section 80P

erred in conforming the same. The same needs cancellation. 5. The Ld. A.O. erred in law as well as on facts in charging interest U/s 234C of Rs. 2,848/-. The Ld. CIT(A) has also erred in conforming the same. The same needs cancellation. 6. The Ld. A.O. erred ... erred in conforming the same. The same needs cancellation. 5. The Ld. A.O. erred in law as well as on facts in charging interest u/s 234C of Rs. 3681/-. The Ld. CIT(A) has also erred in conforming the same. The same needs cancellation. 6. The Ld. A.O. erred

Kanatalaw Seva Sahakari Mandali Ltd., Rajkot (Amreli) vs. The ITO Ward - 3 (1) (4) Amreli, Amreli

ITA 200/RJT/2025[2018-19]Status: DisposedITAT Rajkot06 Nov 2025AY 2018-19

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./ Ita Nos.200 & 201/Rjt/2025 "नधा"रण वष"/Assessment Years :2018-19 & 2019-20 Kanatalaw Seva Sahkari Mandli Income Tax Officer Limited Ward 3(1)(4), Amreli बनाम/ Kanatalaw, Savarkundla, Vs Amreli - 364515 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aakfk8797L (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Written Submission राज"व क" ओर से/Revenue By : Shri Dheeraj Kumr Gupta, Ld. Sr-Dr सुनवाई क" तार"ख /Date Of Hearing : 10/09/2025 घोषणा क" तार"ख /Date Of Pronouncement : 06/11/2025 आदेश/Order Per, Dr. Arjun Lal Saini, A.M

For Appellant: Written SubmissionFor Respondent: Shri Dheeraj Kumr Gupta, Ld. Sr-DR
Section 143(1)Section 234ASection 234BSection 234CSection 250Section 80P

erred in conforming the same. The same needs cancellation. 5. The Ld. A.O. erred in law as well as on facts in charging interest U/s 234C of Rs. 2,848/-. The Ld. CIT(A) has also erred in conforming the same. The same needs cancellation. 6. The Ld. A.O. erred ... erred in conforming the same. The same needs cancellation. 5. The Ld. A.O. erred in law as well as on facts in charging interest u/s 234C of Rs. 3681/-. The Ld. CIT(A) has also erred in conforming the same. The same needs cancellation. 6. The Ld. A.O. erred

Tata Consumer Products Limited (Successor of Tata Coffee Ltd.), Kolkata vs. A.C.I.T., Circle - 4(1), Kolkata

Appeal of the assessee is partly allowed

ITA 2636/KOL/2024[2021-2022]Status: DisposedITAT Kolkata27 Oct 2025AY 2021-2022

Bench: SHRI GEORGE MATHAN, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 143(3)Section 144Section 144BSection 144C(5)Section 153Section 438Section 43BSection 80MSection 928Section 92B

facts and circumstances of the case and in law, the Ld. AO. erred in computing consequential interest u/s 234C of the Act of INR 68,668/-, which is erroneous and not as per law. 10.0 The Ld. AO has grossly erred in initiating penalty proceedings u/s 270A

Sicpa India Private Limited, Delhi vs. Assistant Commissioner of Income-Tax, Circle 22(2), Delhi

In the result, the appeal of the assessee is allowed

ITA 330/DEL/2025[2020-21]Status: DisposedITAT Delhi17 Oct 2025AY 2020-21

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal[ Sicpa India Private Limited, Asst. Cit, 308-312, Mercantile House, Circle -22(2), 15 K.G. Marg, Vs. Delhi. Delhi-110001. Pan-Aadcs6121L (Appellant) (Respondent) Assessee By Shri Akash Singhal, Ca Department By Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 22/07/2025 Date Of Pronouncement 17/10/2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-24, New Delhi [Cit(A), In Short] Dated 28.11.2024 In Appeal No. Nfac/2019-20/10183865 Arising Out Of Order Passed U/S 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) Dated 30.09.2022 For Assessment Year 2020-21. 2. Brief Facts Of The Case Are That Assessee Is A Company Engaged In The Business Of Manufacturing & Distribution Of Security Inks. The Return Of Income For The Year Under Appeal Was E-Filed On 15.02.2021 Declaring Total Income At Rs.6,74,74,000/-. The Case Of The Assessee Was Taken Up For Scrutiny & The Order Was Passed U/S 143(3) On 30.09.2022 Wherein Disallowance Of Rs.23,09,391/- Was Made On Account Of Dividend Distributions Tax & Educational Cess Claimed By The Assessee As Sicpa India Private Limited Vs. Acit Expenses & Further Disallowance U/S 14A Of Rs.25,56,078/- Was Made & The Total Income Of The Assessee Was Assessed At Rs.7,71,05,940/-.

Section 143(3)Section 14ASection 234CSection 270A

initiate proceedings under section 270A of the Act r.w.s 274 of the Act. 3. That the learned AO has further erred in levying interest u/s 234C of the Act which is not applicable on the facts of the instant case. 4. That the Appellant craves leave to add, to amend ... initiation of penalty proceedings u/s 270A of the Act which is premature and Ground of appeal No.3 is with respect to levy of interest u/s 234C of the Act. Since the interest u/s 234C is to be charged on the returned income thus the AO is directed to charge

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

The appeals are allowed with event to follow accordingly

ITA 2211/DEL/2025[2023-24]Status: DisposedITAT Delhi12 Sept 2025AY 2023-24

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

rate 30% instead of normal slab rate applicable and surcharge has been levied @ 37% instead of assessee’s claim of 15% and, further interest u/s 234C of the Act have been levied. The ld. CIT(A) has confirmed the tax levied by the AO at the flat rate ... Finance Act /- and, hence, surcharge is payable on such income @ 15% and not @ 37%. Similarly, as far as the levying of interest u/s 234C of the Act is concerned, it was submitted that the same is consequential. 4. Although ld. DR has defended the orders of the ld. tax authorities