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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

Bravura Solutions India LLP, New Delhi vs. Deputy Commissioner of Income Tax, New Delhi

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

ITA 3944/DEL/2024[2020-21]Status: DisposedITAT Delhi22 Apr 2025AY 2020-21

Bench: Shri Mahavir Singh & Shri M. Balaganeshbravura Solutions India Llp, Vs. Assessment Unit, P-24, Green Park Extension, Income Tax New Delhi-110016 Department, (Appellant) (Respondent) Pan: Aaqfb3843C

For Appellant: Shri Ajay Jain, ARFor Respondent: Shri Dharm Veer Singh, CIT DR
Section 143(3)Section 144BSection 144C(13)Section 144C(3)Section 92BSection 92C

interest u/s 234A 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 settled that the same has to be charged only on the returned income and not on the assessed income

DCIT 2 2 1, Mumbai vs. Yes Bank Limited, Mumbai

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

ITA 992/MUM/2025[2020-21]Status: DisposedITAT Mumbai21 Apr 2025AY 2020-21

Bench: Shrinarendra Kumar Billaiya & Shri Anikesh Banerjeeyes Bank Limited Vs Additional Commissioner Of Income Yes Bank House, 8Th Floor, Tax (Appeals), Panchkula Prabhat Colony, Off Western Express Highway, Santacruz East, Mumbai-400 055 Pan : Aaacy2068D Appellant Respondent Additional Commissioner Of Vs Yes Bank Limited Yes Bank House, 8Th Floor Income Tax (Appeals), Panchkula Prabhat Colony, Off Western Express Highway, Santacruz East, Mumbai-400 055 Pan : Aaacy2068D Appellant Respondent

For Appellant: Shri Yogesh Thard &Ms.Vidhi SalotFor Respondent: Ms. Ramapriya Raghavan - CIT DR&
Section 139(1)Section 143(1)Section 234ASection 234CSection 250Section 36(1)(va)Section 43B

disallowance u/s 36(1)(va) of the Act amounting to Rs. 9,44,99,290/- be deleted. GROUND NO. GROUND II. LEVY OF INTEREST U/S 234C OF THE ACT: 1. On the facts and circumstances of the case and in law, the Hon’ble JCIT(A) erred in confirming ... additional levy of interest u/s 234C of the Act amounting Rs. 17,37,64,891/- as consequential in nature. 3 ITA 1093/Mum/2025 ITA 992/Mum/2025 Yes Bank Ltd 2. The Hon’ble JCIT(A) failed to appreciate and ought to have held that interest u/s 234C is chargeable on returned income

Yes Bank Limited, Mumbai vs. Additional Commissioner of Income Tax (Appeals), Panchkula

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

ITA 1093/MUM/2025[2020-21]Status: DisposedITAT Mumbai21 Apr 2025AY 2020-21

Bench: Shrinarendra Kumar Billaiya & Shri Anikesh Banerjeeyes Bank Limited Vs Additional Commissioner Of Income Yes Bank House, 8Th Floor, Tax (Appeals), Panchkula Prabhat Colony, Off Western Express Highway, Santacruz East, Mumbai-400 055 Pan : Aaacy2068D Appellant Respondent Additional Commissioner Of Vs Yes Bank Limited Yes Bank House, 8Th Floor Income Tax (Appeals), Panchkula Prabhat Colony, Off Western Express Highway, Santacruz East, Mumbai-400 055 Pan : Aaacy2068D Appellant Respondent

For Appellant: Shri Yogesh Thard &Ms.Vidhi SalotFor Respondent: Ms. Ramapriya Raghavan - CIT DR&
Section 139(1)Section 143(1)Section 234ASection 234CSection 250Section 36(1)(va)Section 43B

disallowance u/s 36(1)(va) of the Act amounting to Rs. 9,44,99,290/- be deleted. GROUND NO. GROUND II. LEVY OF INTEREST U/S 234C OF THE ACT: 1. On the facts and circumstances of the case and in law, the Hon’ble JCIT(A) erred in confirming ... additional levy of interest u/s 234C of the Act amounting Rs. 17,37,64,891/- as consequential in nature. 3 ITA 1093/Mum/2025 ITA 992/Mum/2025 Yes Bank Ltd 2. The Hon’ble JCIT(A) failed to appreciate and ought to have held that interest u/s 234C is chargeable on returned income

Tupperware India Private Limited, New Delhi vs. DCIT, Circle-25(1), New Delhi

In the result, the appeal of the assessee for AY 2018-19 is partly allowed for statistical purposes

ITA 462/DEL/2022[2017-18]Status: DisposedITAT Delhi17 Apr 2025AY 2017-18

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Rohit Tiwari, AdvFor Respondent: Shri S. K. Jadav, CIT DR
Section 143(3)Section 144BSection 144CSection 144C(3)Section 92CSection 92F

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “I”: NEW DELHI BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT AND SHRI M. BALAGANESH, ACCOUNTANT

Tupperware India Private Limited, New Delhi vs. ACIT, Circle-25(1), New Delhi

In the result, the appeal of the assessee for AY 2018-19 is partly allowed for statistical purposes

ITA 2409/DEL/2022[2018-19]Status: DisposedITAT Delhi17 Apr 2025AY 2018-19

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Rohit Tiwari, AdvFor Respondent: Shri S. K. Jadav, CIT DR
Section 143(3)Section 144BSection 144CSection 144C(3)Section 92CSection 92F

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “I”: NEW DELHI BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT AND SHRI M. BALAGANESH, ACCOUNTANT

Oakton Global Technology Services Centre (I) Private Limited, Hyderabad vs. Dy. Commissioner of Income Tax, Circle-16(2), Hyderabad

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

ITA 32/HYD/2019[2014-15]Status: DisposedITAT Hyderabad16 Apr 2025AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Ravi Bharadawaj, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(3)Section 92B

invoices raised relating to provision of services. CORPORATE TAX ISSUES 12) Levy of interest u/s 234B on the TP adjustment. 13) Levy of interest u/s 234C of the Act. 14) Initiating proceedings u/s 271AA and 271BA of the Act. The Appellant craves, to consider each of the above grounds ... facts and circumstances of the Case, the Ld. AO has grossly erred in law as well as in facts in computing the interest u/s 234C of the Act amounting to Rs.4,11,702 and the same is consequential to the above grounds. 17. Levy of penalty under section 271AA

Oakton Global Technology Services Centre (India) Private Limited, Hyderabad vs. Deputy Commissioner of Income Tax, Circle-16(2), Hyderabad

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

ITA 2130/HYD/2017[2013-14]Status: DisposedITAT Hyderabad16 Apr 2025AY 2013-14

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Ravi Bharadawaj, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(3)Section 92B

invoices raised relating to provision of services. CORPORATE TAX ISSUES 12) Levy of interest u/s 234B on the TP adjustment. 13) Levy of interest u/s 234C of the Act. 14) Initiating proceedings u/s 271AA and 271BA of the Act. The Appellant craves, to consider each of the above grounds ... facts and circumstances of the Case, the Ld. AO has grossly erred in law as well as in facts in computing the interest u/s 234C of the Act amounting to Rs.4,11,702 and the same is consequential to the above grounds. 17. Levy of penalty under section 271AA

Dr Reddys Laboratories Limited, Hyderabad vs. Deputy Commissioner of Income-Tax, Circle-8(1), Hyderabad

In the result, the appeal filed by the assessee is dismissed

ITA 409/HYD/2023[2011-12]Status: DisposedITAT Hyderabad07 Apr 2025AY 2011-12

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G., Hon’Bleआ.अपी.सं /Ita No.409/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2011-12) Dr. Reddy’S Laboratories Deputy Commissioner Limited Vs. Of Income Tax Hyderabad Circle-8(1) [Pan: Aaacd7999Q] Hyderabad (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri S.P.Chidambaram, Ar राज" व "ारा/Revenue By: Shri B.Bala Krishna, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 09/01/2025 घोषणा की तारीख/Date Of 07/04/2025 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 09.06.2023 Of The Learned Commissioner Of Income Tax (Appeals) [Ld.Cit(A)], National Faceless Appeal Centre, Delhi, Pertaining To A.Y.2011-12. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri S.P.Chidambaram, ARFor Respondent: Shri B.Bala Krishna, CIT-DR
Section 115JSection 143(3)Section 147Section 148Section 154Section 234C

assets without considering the detailed submission of assessee. 7. The learned CIT(A) erred in not adjudicating the ground of appeal pertaining to interest u/s 234C. 8. Appellant reserves the right to add / modify any grounds during the course of the proceeding before ITAT”. 3. The brief facts

DCIT Cir 7(1), Mumbai vs. Novartis India Ltd, Mumbai

In the result, all the appeals of assessee and revenue and the cross objections of the assessee are partly allowed in the aforesaid terms

ITA 4700/MUM/2013[2006-07]Status: DisposedITAT Mumbai21 Mar 2025AY 2006-07

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Shri B R Baskaran, Hon’Ble

For Appellant: Shri J D Mistry, Sr. AdvocateFor Respondent: Shri Kailash C Kanojiya, CIT-DR

above said three years. 18. The next issue urged in AY 2004-05 in Ground no.15 is the manner of charging of interest u/s 234C of the Act. As per the provisions of sec.234C of the Act, the interest under that section should be charged on the returned Novartis India ... accordingly submitted that the same requires correction. 18.1 We heard the parties on this issue. There should not be any dispute that the interest u/s 234C is required to be computed on the returned income. Accordingly, we restore this issue to the file of the AO for computing interest u/s

DCIT Cir 7(1), Mumbai vs. Novartis India Ltd, Mumbai

In the result, all the appeals of assessee and revenue and the cross objections of the assessee are partly allowed in the aforesaid terms

ITA 4699/MUM/2013[2004-05]Status: DisposedITAT Mumbai21 Mar 2025AY 2004-05

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Shri B R Baskaran, Hon’Ble

For Appellant: Shri J D Mistry, Sr. AdvocateFor Respondent: Shri Kailash C Kanojiya, CIT-DR

above said three years. 18. The next issue urged in AY 2004-05 in Ground no.15 is the manner of charging of interest u/s 234C of the Act. As per the provisions of sec.234C of the Act, the interest under that section should be charged on the returned Novartis India ... accordingly submitted that the same requires correction. 18.1 We heard the parties on this issue. There should not be any dispute that the interest u/s 234C is required to be computed on the returned income. Accordingly, we restore this issue to the file of the AO for computing interest u/s

Novartis India Ltd, Mumbai vs. Addl CIT 7(1), Mumbai

In the result, all the appeals of assessee and revenue and the cross objections of the assessee are partly allowed in the aforesaid terms

ITA 4574/MUM/2013[2006-07]Status: DisposedITAT Mumbai21 Mar 2025AY 2006-07

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Shri B R Baskaran, Hon’Ble

For Appellant: Shri J D Mistry, Sr. AdvocateFor Respondent: Shri Kailash C Kanojiya, CIT-DR

above said three years. 18. The next issue urged in AY 2004-05 in Ground no.15 is the manner of charging of interest u/s 234C of the Act. As per the provisions of sec.234C of the Act, the interest under that section should be charged on the returned Novartis India ... accordingly submitted that the same requires correction. 18.1 We heard the parties on this issue. There should not be any dispute that the interest u/s 234C is required to be computed on the returned income. Accordingly, we restore this issue to the file of the AO for computing interest u/s

Novartis India Ltd, Mumbai vs. Addl CIT 7(1), Mumbai

In the result, all the appeals of assessee and revenue and the cross objections of the assessee are partly allowed in the aforesaid terms

ITA 4573/MUM/2013[2004-05]Status: DisposedITAT Mumbai21 Mar 2025AY 2004-05

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Shri B R Baskaran, Hon’Ble

For Appellant: Shri J D Mistry, Sr. AdvocateFor Respondent: Shri Kailash C Kanojiya, CIT-DR

above said three years. 18. The next issue urged in AY 2004-05 in Ground no.15 is the manner of charging of interest u/s 234C of the Act. As per the provisions of sec.234C of the Act, the interest under that section should be charged on the returned Novartis India ... accordingly submitted that the same requires correction. 18.1 We heard the parties on this issue. There should not be any dispute that the interest u/s 234C is required to be computed on the returned income. Accordingly, we restore this issue to the file of the AO for computing interest u/s

ACIT Cir 7(1), Mumbai vs. Novartis India Ltd, Mumbai

In the result, all the appeals of assessee and revenue and the cross

ITA 7799/MUM/2012[2007-08]Status: DisposedITAT Mumbai21 Mar 2025AY 2007-08

Bench: Justice (Retd.) C V Bhadang, Hon'Ble & Shri B R Baskaran, Hon'Ble

For Appellant: Shri J D Mistry, Sr. AdvocateFor Respondent: Shri Kailash C Kanojiya, CIT-DR

above said three years. 18. The next issue urged in AY 2004-05 in Ground no.15 is the manner of charging of interest u/s 234C of the Act. As per the provisions of sec.234C of the Act, the interest under that section should be charged on the returned income ... accordingly submitted that the same requires correction. 18.1 We heard the parties on this issue. There should not be any dispute that the interest u/s 234C is required to be computed on the returned income. Accordingly, we restore this issue to the file of the AO for computing interest u/s

Novartis India Ltd, Mumbai vs. Asst CIT 7(1), Mumbai

In the result, all the appeals of assessee and revenue and the cross objections of the assessee are partly allowed in the aforesaid terms

ITA 7733/MUM/2012[2007-08]Status: DisposedITAT Mumbai21 Mar 2025AY 2007-08

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Shri B R Baskaran, Hon’Ble

For Appellant: Shri J D Mistry, Sr. AdvocateFor Respondent: Shri Kailash C Kanojiya, CIT-DR

above said three years. 18. The next issue urged in AY 2004-05 in Ground no.15 is the manner of charging of interest u/s 234C of the Act. As per the provisions of sec.234C of the Act, the interest under that section should be charged on the returned Novartis India ... accordingly submitted that the same requires correction. 18.1 We heard the parties on this issue. There should not be any dispute that the interest u/s 234C is required to be computed on the returned income. Accordingly, we restore this issue to the file of the AO for computing interest u/s

Anand Mahabal Shetty, Mumbai vs. Assistant Director of Income Tax, CPC., Bangalore

In the result, the appeal of the appellant is allowed

ITA 593/MUM/2025[2019-20]Status: DisposedITAT Mumbai18 Mar 2025AY 2019-20

Bench: Shri Om Prakash Kant (Am) & Smt. Kavitha Rajagopal (Jm) Anand Mahabal Shetty Adit, Cpc, C/402, Chavandai Chs Bangalore/Acit Opposite Rajpark, Parsik Vs. Qureshi Mansion Nagar, Kalwa, Thane Gokhale Road Mumbai-400 060. Thane-400 602. Pan : Aopps4358Q Appellant Respondent

For Appellant: Shri Ram Krishn KediaFor Respondent: None
Section 119(2)(b)Section 139(1)Section 234BSection 234CSection 90

Anand Mahabal Shetty 3. erred in levying additional interest of Rs. 8,87,860 /- under section 234B of the Act; Interest u/s 234C of the Act; 4. erred in levying additional interest of Rs. 1,80,657/- under section 234C of the Act; without appreciation interest u/s 234C

DCIT Cen 8.2, Mumbai vs. Karamtara Engineering Private Limited, Mumbai

ITA 4877/MUM/2024[2011-12]Status: DisposedITAT Mumbai18 Mar 2025AY 2011-12

Bench: Shri Sandeep Gosain (Jm) & Shri Omkareshwar Chidara (Am) Dcit, Cen. Circle-8(1) Karamtara Engineering 565, 6Th Floor Private Limited Aayakar Bhavan Vs. 705, Morya Land Mark M.K. Road Andheri West Mumbai-400 020. Mumbai-400 053. Pan : Aabck1921E Appellant Respondent

For Respondent: Shri Priyank Ghia &
Section 234BSection 234C

without considering the facts & circumstances of the case. The same be considered. 4. The Learned A.O. erred in levying interest u/s 234C of Income Tax Act, 1961 without considering the fact that interest u/s 234C is applicable on retuned income and not on assessed income. The same be considered

Mr Vishal Subhashgir Giri, Aurangabad vs. ITO, Ward-1(5), Aurangabad

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

ITA 254/PUN/2025[2017-18]Status: DisposedITAT Pune11 Mar 2025AY 2017-18

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.254/Pun/2025 धििाारण वषा / Assessment Year: 2017-2018 Mr. Vishal Subhashgir Vs Ito, Ward-1(5), Giri, Aurangabad 5, At Nimbayti, Post- Bahulkhede, Tal-Soygaon, Dist. Aurangabad-431120 Maharashtra Pan-Ayqpg9023P Appellant Respondent

For Appellant: Shri Abhay AvachatFor Respondent: Shri Aviyogi Ambadkar
Section 144Section 234CSection 250Section 69A

provisions of section 69A despite the same were not applicable to assessee's case, 7. The learned AO is not justified in charging interest u/s 234C and the same may please be cancelled as Interest u/s 234C is applicable only on Returned Income and not assessed income. 8. The lower

Harsco India Private Limited, Hyderabad vs. DCIT., Circle 2(1), Hyderabad

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

ITA 1041/HYD/2024[2021-22]Status: DisposedITAT Hyderabad06 Mar 2025AY 2021-22

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita No.1041/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2021-22) Harsco India (P) Ltd Vs. Dy. Commissioner Of Hyderabad Income Tax, Circle 2(1) Pan:Aacch0555L Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca Suvibha Nolka राज" व "ारा/Revenue By:: Shri B Bala Krishna, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 08/01/2025 घोषणा की तारीख/Pronouncement: 06/03/2025 आदेश/Order

For Appellant: CA Suvibha NolkaFor Respondent: : Shri B Bala Krishna, CIT(DR)
Section 143(3)Section 144C(5)

days as a normal credit period without any interest. 11. In Ground No.8, the assessee has raised the objection regarding incorrect computation of interest u/s 234C of the I.T. Act, 1961. The levy of interest u/s 234C is mandatory and consequential. Accordingly, the Assessing Officer is directed to recompute

Smit Chhaganbhai Ardeshna, Alka Society Akota Vadodara vs. AO, Vadodara

In the result, the appeal of the assessee is dismissed

ITA 1534/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad12 Feb 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: NoneFor Respondent: Ms. Ketaki Desai, Sr. DR
Section 234BSection 234C

charging interest u/s 234B of the Act. 7. The leaned AO erred in fact and in Law in charging interest u/s 234C of the Act. 8. Your Appellant craves the right to add, to alter, to substitute, delete or modify all or any of the above grounds of Appeal

The Janseva Trust, Godhra vs. The Income Tax Officer, Ward 4(1)(2), Vadodara (Now Income Tax Officer, Ward 1, Godhra)

In the result, the appeal of the assessee is allowed for statistical purposes, subject to the above directions

ITA 851/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad29 Jan 2025AY 2017-18

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.851/Ahd/2023 िनधा"रण वष" /Assessment Year : 2017-18 The Janseva Trust The Ito बनाम/ Opp. Gyandeep School Ward-4(1)(1)(2), Vadodara V/S. Nr.Jivanlal Hospital (Now Ito, Ward-1, Godhra – 389 001 (Gujarat) Godhra – 389 001) "थायी लेखा सं./Pan: Aaatt 2888 D (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Ms. Nikhita Bhamblani & Amrin Pathan, Ars Revenue By : Shri Rignesh Das, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 27/01/2025 घोषणा की तारीख /Date Of Pronouncement: 29/01/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: The Present Appeal Has Been Filed By The Assessee Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], Dated 29.08.2023, For The Assessment Year (A.Y.) 2017-18. The Said Appeal Arises From The Assessment Order Passed By The Income Tax Officer (Ito), Ward 4(1)(2), Vadodara [Hereinafter Referred To As “Ao”], Under Section 144 Of The Income Tax Act, 1961 [Hereinafter Referred To As “The Act)”], On 24.12.2019. The Janseva Trust Vs. Ito Asst. Year : 2017-18

For Appellant: Ms. Nikhita Bhamblani &For Respondent: Shri Rignesh Das, Sr.DR
Section 115BSection 139(1)Section 142(1)Section 144Section 69A

confirming interest u/s 234B of the Act. 17. The learned CIT(A) erred in fact and in law in confirming interest u/s 234C of the Act. 18. The learned CIT(A) erred in fact and in law in initiating penalty proceedings u/s 271F of the Act. 19. The learned