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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

Dcm Shriram Limited, Delhi vs. Assessment Unit, Delhi

ITA 4328/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Jun 2025AY 2020-21

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 115JSection 143(3)Section 250Section 80GSection 80ISection 92C

income, nor any other default according to law by the assessee. 15. That the Ld. A.O has erred in law in charging interest u/s 234C of the Act on wholly illegal and untenable grounds.” 34. Ground No. 1 is general in nature needs no separate adjudication. 35. Ground Nos.2

Amit Upadhyay, Faridabad vs. Income Tax Officer, Ward-1(5), Faridabad

In the result, the appeal of the assessee is allowed

ITA 3046/DEL/2023[2017-18]Status: DisposedITAT Delhi30 Jun 2025AY 2017-18

Bench: Shri C. N. Prasad & Shri M. Balaganeshsh. Amit Upadhyay Vs. Income Tax Officer, Flat No.101, Prem Co. Ward-1(5), Pvt. Society Sector- Faridabad 21C, Faridabad-121001 (Appellant) (Respondent) Pan: Abepu0188Q

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 115BSection 143(3)Section 69A

With regard to chargeability of interest u/s 234B of the Act, the same is consequential. With regard to chargeability of 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

DCIT, New Delhi vs. Dcm Shriram Ltd, New Delhi

ITA 927/DEL/2022[2015-16]Status: DisposedITAT Delhi30 Jun 2025AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 115JSection 143(3)Section 250Section 80GSection 80ISection 92C

income, nor any other default according to law by the assessee. 15. That the Ld. A.O has erred in law in charging interest u/s 234C of the Act on wholly illegal and untenable grounds.” 34. Ground No. 1 is general in nature needs no separate adjudication. 35. Ground Nos.2

Dcm Shriram Ltd, New Delhi vs. ACIT, Circle-7(1), New Delhi

ITA 2587/DEL/2022[2018-19]Status: DisposedITAT Delhi30 Jun 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 115JSection 143(3)Section 250Section 80GSection 80ISection 92C

income, nor any other default according to law by the assessee. 15. That the Ld. A.O has erred in law in charging interest u/s 234C of the Act on wholly illegal and untenable grounds.” 34. Ground No. 1 is general in nature needs no separate adjudication. 35. Ground Nos.2

Dcm Shriiram Limited, New Delhi vs. Neac, New Delhi

ITA 704/DEL/2021[2016-17]Status: DisposedITAT Delhi30 Jun 2025AY 2016-17

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 115JSection 143(3)Section 250Section 80GSection 80ISection 92C

income, nor any other default according to law by the assessee. 15. That the Ld. A.O has erred in law in charging interest u/s 234C of the Act on wholly illegal and untenable grounds.” 34. Ground No. 1 is general in nature needs no separate adjudication. 35. Ground Nos.2

Seri Multiple Asset Investment, Kolkata vs. ACIT, Cir-29, Kolkata

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

ITA 2630/KOL/2024[2016-17]Status: DisposedITAT Kolkata25 Jun 2025AY 2016-17

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 143(3)Section 234CSection 250

circumstances of the case, the Ld. CIT(Appeals) was not justified rather grossly erred in ignoring the action of the AO in levying interest u/s 234C without appreciating the fact that such interest is liable to be computed on the returned income. 7. That the appellant craves leave

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)

Income Tax Act, 1961 („the Act‟) at the returned income of Rs. 2,13,37,530/-. In the intimation, the AO has levied interest u/s. 234C of the Act amounting to Rs. 1,08,236/- as against the interest computed by the assessee at Rs. 7,590/-. The assessee carried ... matter in appeal before the Ld.CIT(A), who has since sustained the levy of interest u/s. 234C of the Act holding the same as consequential in nature and against such finding, the assessee is in appeal before us. 3. During the course of hearing, Ld.AR submitted that the grievance

Shanmughasundharamramanathan, Chennai vs. ITO, Ncw-10(6), Chennai

ITA 888/CHNY/2025[2017-18]Status: DisposedITAT Chennai18 Jun 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.888/Chny/2025 िनधा8रण वष8 /Assessment Year: 2017-18 Shanmughasundharam The Income Tax Officer, Ramanathan, Vs. Non Corporate Ward-10(6), No.45, Theosophical Society, Chennai. Adyar, Chennai – 600 020. [Pan: Aafps 6078P]

For Appellant: Shri G. Akash, Advocate
Section 143(3)Section 234ASection 234CSection 234D

event, the interest levied is high, arbitrary and excessive which needs to be deleted in toto. 4. The AO erred in levying interest u/s 234C amounting to Rs.76,426/- and u/s 234D amounting to Rs.1,65,053/-.In any event, the interest le vied is high, arbitrary and excessive which

Mcleod Russel India Limited, Kolkata vs. A.C.I.T., Circle-4(1), Kolkata

The appeals of the assessee are partly allowed

ITA 458/KOL/2022[2018-2019]Status: DisposedITAT Kolkata17 Jun 2025AY 2018-2019

Bench: the due date of filing of return under Section 139(1) of the Act.

Section 115JSection 139(1)Section 143(3)Section 14ASection 2(24)(x)Section 36(1)(va)Section 37

that the Assessing Officer has erred in law and on facts in computing interest u/s 234B at Rs 5,95,96,264/- and interest u/s 234C at Rs 1,02,41,996/-. Mecleod Russel India Ltd. 12. The Appellant craves leave to add, alter, amend and/or withdraw ... allowed for statistical purposes. 21. Ground No. 11 protests the charge of interest u/s 234B at Rs. 5,95,96,264/- and interest u/s 234C at Rs. 1,02,41,996/-. We find that the charging of interest would be consequential upon the final Mecleod Russel India Ltd. determination

Mecleod Russel India Ltd., Kolkata vs. A.C.I.T., Circle - 4(1), Kolkata

The appeals of the assessee are partly allowed

ITA 454/KOL/2022[2017-2018]Status: DisposedITAT Kolkata17 Jun 2025AY 2017-2018

Bench: the due date of filing of return u/s 139(1) of the Act.

Section 115JSection 139(1)Section 143(3)Section 14ASection 2(24)(x)Section 36(1)(va)Section 37

that the Assessing Officer has erred in law and on facts in computing interest u/s 234B at Rs 5,95,96,264/- and interest u/s 234C at Rs 1,02,41,996/-. Mecleod Russel India Ltd. 12. The Appellant craves leave to add, alter, amend and/or withdraw ... allowed for statistical purposes. 21. Ground No. 11 protests the charge of interest u/s 234B at Rs. 5,95,96,264/- and interest u/s 234C at Rs. 1,02,41,996/-. We find that the charging of interest would be consequential upon the final Mecleod Russel India Ltd. determination

Jindal Saw Ltd., New Delhi vs. ACIT, Circle-13(2), New Delhi

In the result, assessee’s appeal in ITA No

ITA 504/DEL/2022[2014-15]Status: DisposedITAT Delhi04 Jun 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2011-12] Jindal Saw Ltd. Vs Dcit, 28, Najafgarh Road, Circle-13(2) New Delhi-110015. (Earlier Addl.Cit Range-4), Pan-Aabcs7280C C.R.Building, I.P.Estate, New Delhi-110002. Appellant Respondent [Assessment Year : 2011-12] Dcit, Vs Jindal Saw Ltd. Circle-13(2), (Formerly Known As M/S. Saw Pipes Room No.316A, Ltd.), 28, Najafgarh Road, C.R.Building, New Delhi-110015. New Delhi Pan-Aabcs7280C Appellant Respondent [Assessment Year : 2014-15] Jindal Saw Ltd., Vs Acit, 28, Najafgarh Road, Shivaji Marg, Circle-13(2), New Delhi-110015. New Delhi. Pan-Aabcs7280C Appellant Respondent [Assessment Year : 2015-16] Jindal Saw Ltd. Vs Acit, 28, Najafgarh Road, Circle-13(2) P.O.Ramesh Nagar, C.R.Building, I.P.Estate, New Delhi-110015. New Delhi-110002. Pan-Aabcs7280C Appellant Respondent

Section 143(3)Section 234BSection 43B

consequential in nature and interest u/s 234D is on account of refund already issued to the assessee. With regard to the levy of interest u/s 234C, Ld.AR argued that interest u/s 234C is leviable for the default in payment of advance tax installments and is payable at the time ... filing of return of income. Since advance tax is to be calculated on the basis of estimation of income, thus the interest u/s 234C is to be levied on the income declared in return filed by the assessee however, in the instant case the interest u/s 234C is charged

DCIT Circle-13(2), New Delhi vs. Jindal Saw Ltd., New Delhi

In the result, assessee’s appeal in ITA No

ITA 4760/DEL/2019[2015-16]Status: DisposedITAT Delhi04 Jun 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2011-12] Jindal Saw Ltd. Vs Dcit, 28, Najafgarh Road, Circle-13(2) New Delhi-110015. (Earlier Addl.Cit Range-4), Pan-Aabcs7280C C.R.Building, I.P.Estate, New Delhi-110002. Appellant Respondent [Assessment Year : 2011-12] Dcit, Vs Jindal Saw Ltd. Circle-13(2), (Formerly Known As M/S. Saw Pipes Room No.316A, Ltd.), 28, Najafgarh Road, C.R.Building, New Delhi-110015. New Delhi Pan-Aabcs7280C Appellant Respondent [Assessment Year : 2014-15] Jindal Saw Ltd., Vs Acit, 28, Najafgarh Road, Shivaji Marg, Circle-13(2), New Delhi-110015. New Delhi. Pan-Aabcs7280C Appellant Respondent [Assessment Year : 2015-16] Jindal Saw Ltd. Vs Acit, 28, Najafgarh Road, Circle-13(2) P.O.Ramesh Nagar, C.R.Building, I.P.Estate, New Delhi-110015. New Delhi-110002. Pan-Aabcs7280C Appellant Respondent

Section 143(3)Section 234BSection 43B

consequential in nature and interest u/s 234D is on account of refund already issued to the assessee. With regard to the levy of interest u/s 234C, Ld.AR argued that interest u/s 234C is leviable for the default in payment of advance tax installments and is payable at the time ... filing of return of income. Since advance tax is to be calculated on the basis of estimation of income, thus the interest u/s 234C is to be levied on the income declared in return filed by the assessee however, in the instant case the interest u/s 234C is charged

Jindal Saw Ltd., New Delhi vs. ACIT Circle-13(2), New Delhi

In the result, assessee’s appeal in ITA No

ITA 4693/DEL/2019[2015-16]Status: DisposedITAT Delhi04 Jun 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2011-12] Jindal Saw Ltd. Vs Dcit, 28, Najafgarh Road, Circle-13(2) New Delhi-110015. (Earlier Addl.Cit Range-4), Pan-Aabcs7280C C.R.Building, I.P.Estate, New Delhi-110002. Appellant Respondent [Assessment Year : 2011-12] Dcit, Vs Jindal Saw Ltd. Circle-13(2), (Formerly Known As M/S. Saw Pipes Room No.316A, Ltd.), 28, Najafgarh Road, C.R.Building, New Delhi-110015. New Delhi Pan-Aabcs7280C Appellant Respondent [Assessment Year : 2014-15] Jindal Saw Ltd., Vs Acit, 28, Najafgarh Road, Shivaji Marg, Circle-13(2), New Delhi-110015. New Delhi. Pan-Aabcs7280C Appellant Respondent [Assessment Year : 2015-16] Jindal Saw Ltd. Vs Acit, 28, Najafgarh Road, Circle-13(2) P.O.Ramesh Nagar, C.R.Building, I.P.Estate, New Delhi-110015. New Delhi-110002. Pan-Aabcs7280C Appellant Respondent

Section 143(3)Section 234BSection 43B

consequential in nature and interest u/s 234D is on account of refund already issued to the assessee. With regard to the levy of interest u/s 234C, Ld.AR argued that interest u/s 234C is leviable for the default in payment of advance tax installments and is payable at the time ... filing of return of income. Since advance tax is to be calculated on the basis of estimation of income, thus the interest u/s 234C is to be levied on the income declared in return filed by the assessee however, in the instant case the interest u/s 234C is charged

Amitkumar Pravinchandra Reshamwala, Surat vs. Deputy Director of Income Tax, CPC Bengaluru / ITO (Int. Tax) Surat, CPC Bengaluru / ITO Surat

In the result, appeal of assessee is dismissed

ITA 1240/SRT/2024[2023-24]Status: DisposedITAT Surat29 May 2025AY 2023-24

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1240/Srt/2024 Assessment Year: (2023-24) (Hybrid Hearing) Amitkumar Pravinchandra Deputy Director Of Income-Tax, बनाम/ Reshamwala Cpc, Bengaluru/Ao (Int. Tax) Vs. B-1004, Arihant Heightsopp Surat Stuti Icon. Auravpath, Palanpur-395 005 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Agspr 4047 K (अपीलाथ"/Appellant) (""थ" /Respondent)

Section 154Section 234BSection 234CSection 250Section 90

submits that the AO/CPC be directed to delete the excess interest so levied and to re-compute its tax liability accordingly. 4. Re.: Interest u/s 234C of the Act has been levied in excess: ITA No.1240/SRT/2024/AY.23-24 Amitkumar P Reshamwala 1. The AO/CPC has erred in levying interest of Rs.1 ... circumstances of this case and the law prevailing on the subject, no further interest is leviable u/s 234C (over and above the interest u/s 234C of Rs.1,3,622/- computed and paid by the appellant at the time of filing its return of income) and hence the action

Hreyansh Vasundhara Family Trust, Pune vs. Income Tax Officer, Ward-7(1), Pune

In the result, the appeal of the assessee is allowed

ITA 1795/PUN/2024[2023-24]Status: DisposedITAT Pune29 May 2025AY 2023-24

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Kiran SanmaneFor Respondent: Shri Ramnath P. Murkunde
Section 111ASection 112Section 112ASection 143(1)Section 167Section 167BSection 2(290)Section 234C

case of short term capital gains u/s 111A, long term capital gains u/s 112A and dividend is 15%. 9. In holding that the interest u/s 234C is mandatory and consequential and recomputing interest by AO CPC u/s 234C at Rs. 4,61,238/- on the basis of assessed income ... correct when, in fact, interest u/s 234C is required to be computed on the basis of total income as per return filed. 10. The Appellant craves leave to add to, withdraw or modify any of the grounds of appeal at the time of hearing.” 3. The common issue raised

Hreyansh Vasundhara Family Trust, Pune vs. Income Tax Officer, Ward-7(1), Pune

In the result, the appeal of the assessee is allowed

ITA 1794/PUN/2024[2022-23]Status: DisposedITAT Pune29 May 2025AY 2022-23

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Kiran SanmaneFor Respondent: Shri Ramnath P. Murkunde
Section 111ASection 112Section 112ASection 143(1)Section 167Section 167BSection 2(290)Section 234C

case of short term capital gains u/s 111A, long term capital gains u/s 112A and dividend is 15%. 9. In holding that the interest u/s 234C is mandatory and consequential and recomputing interest by AO CPC u/s 234C at Rs. 4,61,238/- on the basis of assessed income ... correct when, in fact, interest u/s 234C is required to be computed on the basis of total income as per return filed. 10. The Appellant craves leave to add to, withdraw or modify any of the grounds of appeal at the time of hearing.” 3. The common issue raised

General Organization for Social Insurance, Mumbai vs. The Assistant Commissioner of Income-Tax - (International Taxation) Circle 2(3)(2) - Mumbai, Mumbai

ITA 1408/MUM/2025[2022-2023]Status: DisposedITAT Mumbai22 May 2025AY 2022-2023

Bench: Shri Sandeep Singh Karhailshri Girish Agrawal

For Appellant: Shri Ketan VedFor Respondent: Shri Soumendu Kumar Dash, Sr.DR
Section 142(1)Section 143(2)Section 143(3)Section 144C(13)Section 234CSection 270ASection 274

erred in levying interest of Rs.6,40,881/- u/s.234C of the Income Tax Act, 1961 ('the Act"). 3. 2. The Appellant submits that interest u/s 234C being consequential in nature, the learned ACIT be directed to delete the interest u/s 234C of the Act so levied and to re-compute

S.B. Bhattacharjee Memorial Trust for Children Education, Digboi vs. ACIT, Circle-1, Dibrugarh

In the result, the appeal of the assessee is allowed

ITA 245/GTY/2024[2022-23]Status: DisposedITAT Guwahati09 May 2025AY 2022-23

Bench: Shri Manomohan Das & Shri Rakesh Mishra

Section 11Section 143(1)Section 234ASection 234C

accepting the fact that the returned income was NIL, the ld. Addl. CIT(A) was not justified in not deleting the arbitrarily charged interest u/s 234C of the Act at Rs. 1,40,188/-, which is not in accordance with the law. 11. For that the impugned order having been

Open Text Technologies India Private Limited, Hyderabad vs. Dy. Commissioner of Income Tax, Circle-16(2), Hyderabad

ITA 2387/HYD/2018[2014-15]Status: DisposedITAT Hyderabad05 May 2025AY 2014-15

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Madhusudan Sawdia, Hon'Ble

For Appellant: Revenue byFor Respondent: Date of hearing
Section 143(3)Section 92B

amounting to Rs. 3,11,35,170 and the same is consequential to the above grounds. 15. Erroneous calculation of Interest u/s 234C of the Act. That on facts and circumstances of the Case, the Ld. AO has grossly erred in law as well as in facts in computing ... interest u/s 234C of the Act amounting to Rs.3,82,808 and the same is consequential to the above grounds. 16. Levy of penalty under section 271AA and 271BA of the Act Initiating penalty proceedings under section 271AA and 271BA of the Act." 3. The assessee has raised the additional

Zenobia Phiroze Irani, Chennai vs. ITO, Ncw-3(3), Chennai

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

ITA 2913/CHNY/2024[2023-24]Status: DisposedITAT Chennai23 Apr 2025AY 2023-24

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.2913/Chny/2024, Assessment Years: 2023-24 Zenobia Phiroze Irani, Income Tax Officer, New No.7, Muthiah Street, Non-Corporate, Teynampet, Ward-3(3), Chennai-600 086. Chennai [Pan: Aaapi1704R] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Shri S.Sridhar, Advocate प्रत्यर्थी की ओर से /Revenue By : Smt.Samantha Mullamudi, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 27.03.2025 घोषणा की तारीख /Date Of Pronouncement : 23.04.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Shri S.Sridhar, AdvocateFor Respondent: Smt.Samantha Mullamudi, Addl.CIT
Section 234CSection 234F

different dates as against total liability of Rs.4,35,39,780/-. Thus it was submitted that at best only an interest u/s 234C of Rs.9037/- was liable to be levied on advance tax shortfall of Rs.1,39,780/-. As regards, penalty u/s 234F it was submitted that the return