Section 234C of the Income Tax Act

Income-tax Act, 2025: s.425

Section 234C of the Income-tax Act, 1961 corresponds to section 425 (Interest for deferment of advance tax) of the Income-tax Act, 2025.

Read section 425 of the 2025 Act

Correspondence checked against the ICAI tabular mapping of the two Acts and the BharatTax.co section commentary.

The decision most relied on for Section 234C is CIT v. Tata Elxsi Ltd. (349 ITR 98), cited in 818 of the 6,043 judgments on BharatTax that turn on this section.

Leading authorities on Section 234C

CIT v. Tata Elxsi Ltd.
349 ITR 98 · 2012 · High Court
818
citing judgments

When computing deduction under Section 10A, if communication or telecommunication expenses are excluded from export turnover, they must also be excluded from total turnover to maintain consistency and apply the ordinary meaning of 'turnover' in context.

Rotork Controls India Pvt. Ltd. v. CIT
314 ITR 62 · 2009 · Supreme Court
739
citing judgments

A provision for expenses, such as warranty, is a deductible liability for income tax purposes if it constitutes a present obligation arising from past events, and a reliable estimate of the amount of obligation is possible.

CIT v. State Bank of Bikaner & Jaipur
43 Taxmann.com 411 · 2014 · High Court
524
citing judgments

Employee contributions to provident fund, ESI, and other welfare funds, if deposited by the due date for furnishing the return of income under Section 139(1), are allowable as a deduction and cannot be disallowed under Section 36(1)(va) read with Section 2(24)(x) or Section 43B, even if deposited after the due date prescribed by the respective welfare Acts.

Essae Teraoka Pvt. Ltd. v. DCIT
366 ITR 408 · 2014 · High Court
519
citing judgments

An employer's delayed remittance of employees' contributions to provident fund (PF) or Employees' State Insurance (ESI) is deductible if the payment is made before the due date for filing the income tax return under section 139(1), applying the provisions of section 43B and notwithstanding section 36(1)(va).

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.

India Vs. Azadi Bachao Andolan 263 ITR 706 (SC); and Vodafone International Holdings B.V v. Union of India
341 ITR 1 · 2012 · Supreme Court
295
citing judgments

Legitimate tax planning is permissible, allowing taxpayers to arrange their affairs to minimize tax liabilities while respecting the "look at test" for transaction genuineness and the separate entity principle in corporate taxation. The source of funds for treaty-beneficial structures does not automatically invalidate the transaction.

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.

DIT v. Infrasoft Ltd.
39 Taxmann.com 88 · 2013 · High Court
269
citing judgments

Payments for the use of copyrighted software, without the transfer of any rights in the underlying copyright itself, do not constitute 'royalty' under the Income-tax Act or tax treaties. Such payments are often treated as business income, taxable only if a permanent establishment exists.

M/s Mahadev Cold Storage v. Jurisdictional AO
43 Taxmann.com 33 · 2014 · High Court
262
citing judgments

Employees' contributions to welfare funds are an allowable deduction if paid before the due date for filing the income-tax return under section 139(1), even if the payment is made beyond the due date specified by the respective welfare fund Acts, as per the provisions of section 43B.

Judgments on Section 234C

Madan Lal Jat, Jaipur vs. ITO Ward 7(1), Jaipur

The appeal of the assessee is partly allowed in above terms

ITA 1883/JPR/2025[2013-14]Status: DisposedITAT Jaipur30 Jun 2026AY 2013-14

Bench: Smt. Annapurna Guptamadan Lal Jat Vs. Ito Nitharwalo Ki Dhani, Ward 7(1) Mundli Renwal Jaipur Raj. Jaipur 303603 (Present Address C/O G.S. Stonex, 3/185- Bachamanglam Ring Road Semanur Village Bagur Krishnagiri Tamil Nadu 635108, Jaipur "थायीलेखासं./जीआइआरसं./Pan/Gir No:Bdqpj 0380 Q Appellant .. Respondent Appellant By : Sh. Shrawan Kumar Gupta, Adv. Respondent By : Mrs. Aarti Rawat, Addl. Cit Date Of Hearing 23.06.2026 Date Of Pronouncement 30.06.2026 O R D E R The Present Appeal Has Been Filed By The Assessee Against The Order Passed By The National Faceless Appeal Centre, Delhi (Nfac) (Hereinafter Referred To As “Ld. Cit(A)”), Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) Dated 31- 10-25. P A G E | 2 Madan Lal Jat 2. The Grounds Of Appeal Raised By The Assessee Read As Under:- 1. The Impugned Order U/S 147 Rws 144 Of The I. T. Act, 1961 Dated 24.03.2022 As Well As The Notice U/S 147 Rws 144 & Action Or Proceedings U/S 147/144 Are Illegal, Bad In Law, Barred By Limitation, Without Jurisdiction, Without Approval/Satisfaction From The Proper Or Competent Authority, In Valid Exparty Order In Gross Breach Of The Law & Against The Principle Of Natural Justice & Various Other Reasons Or & Further Contrary To The Real Facts Of The Case Hence The Same May Kindly Be Quashed.

For Appellant: Sh. Shrawan Kumar Gupta, AdvFor Respondent: Mrs. Aarti Rawat, Addl. CIT
Section 147Section 234ASection 250Section 44ASection 68Section 80C