This compilation indexes twelve rulings pronounced by various Income Tax Appellate Tribunal (ITAT) benches between December 2025 and May 2026 in which Section 234A of the Income Tax Act, 1961 was among the statutory provisions engaged. The cases span a wide range of substantive disputes — reassessment validity, deduction claims, penalty proceedings, and transfer-pricing adjustments — across benches in Pune, Nagpur, Surat, Lucknow, Agra, Vizag, Dehradun, Hyderabad, and Kolkata. This index is intended for in-house tax teams, Big-4 associates, and law firm researchers who need a rapid-reference map of recent ITAT activity touching Section 234A.

Research index only. This page catalogues publicly available tribunal orders for research and tracking purposes. Nothing on this page constitutes legal or tax advice. Readers must verify each ruling against the full text of the judgment and check for any subsequent stay, reversal, or further appeal before placing reliance on it.

The statutory framework in one paragraph

Section 234A of the Income Tax Act, 1961 provides for the levy of interest where a taxpayer fails to furnish the return of income within the due date specified under Section 139(1) or, where applicable, within the time allowed under a notice issued under Section 142(1). Interest is charged at the prescribed rate on the amount of tax on total income as determined under the Act (reduced by advance tax paid, TDS/TCS, and certain other credits), computed from the date immediately following the due date for filing the return to the date of furnishing the return or, where no return is furnished, to the date of completion of the assessment. The section operates as a compensatory charge for the period of default and is routinely engaged alongside substantive assessment or appellate proceedings whenever the return-filing timeline is in dispute or the assessed income differs materially from the returned income.

The 12 rulings

1. Sonaj And Company, Solapur vs DCIT Cirlcle 2(2), Solapur

Bench: Income Tax Appellate Tribunal - Pune
Date: 6 May 2026
Sections engaged: 139(8), 142(1), 143(2), 147, 148, 234A, 80P
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed by the assessee, a partnership firm engaged in the business of dealing in petroleum products, Hero Honda motorcycle spare parts, and other commodities, against the order of the Commissioner of Income Tax (Appeals), Pune-11 dated 30.07.2025, pertaining to Assessment Year 1990-91. The source preview records that a search and seizure action was conducted in the case of the assessee on 21.07.1999, following which a notice under Section 158BC was issued on 15.10.1999 requiring the assessee to furnish a return of income for the block period 1990-1991 to 1999-2000. The full substantive findings of the Tribunal are not reproduced in the available source preview.

2. Late Padmadevi R Maloo Foundation vs Income Tax Officer Ward-2,Exemp

Bench: Income Tax Appellate Tribunal - Nagpur
Date: 9 April 2026
Sections engaged: 10, 11, 234A, 250
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 463/NAG/2024) was filed by the assessee against the order of the Addl./JCIT (Appeals)-1, Visakhapatnam, dated 29/06/2024 passed under Section 250, which arose from an intimation dated 17.03.2020 for Assessment Year 2018-19. The source preview notes that the assessee's income applied was Rs. 1,13,36,653/- against gross receipts of Rs. 1,10,52,415/-, and records that it is a settled position of law that in the event the benefit of Section 11 is engaged, consequential questions arise. The full dispositive direction of the Tribunal is not reproduced in the available source preview.

3. Ampacet Speciality Products Private vs Deputy Comissioner Of Income Tax Circle

Bench: Income Tax Appellate Tribunal - Pune
Date: 9 March 2026
Sections engaged: 135, 139(1), 143(1)(a), 234A, 250, 270A, 270A(9)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 1987/PUN/2025) pertains to Assessment Year 2020-21 and was directed against the order dated 02.06.2025 framed by the National Faceless Appeal Centre, Delhi, arising out of an assessment order dated 29.09.2023. The assessee raised grounds contending that the Assessing Officer erred in not considering income as per the return filed under Section 139(1) and instead computed income under Section 143(1)(a), against which the appellant had already filed a response on the income tax e-filing portal; the NFAC was further alleged to have failed to consider this ground while passing its order. The full substantive findings and dispositive direction of the Tribunal are not reproduced in the available source preview.

4. Manish Bhogilal Shah,Mumbai vs Income Tax Officer-3, Navsari, Navsari

Bench: Income Tax Appellate Tribunal - Surat
Date: 27 February 2026
Sections engaged: 147, 234A, 271A, 68, 69C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 687/SRT/2025) for Assessment Year 2017-18 was preferred by the assessee against the order of the CIT(A), National Faceless Appeal Centre, Delhi dated 27/12/2024. The hearing was conducted through hybrid mode at Ahmedabad Bench. The full substantive findings and dispositive direction of the Tribunal are not reproduced in the available source preview.

5. Charak Helth Care & Rural Development vs DCIT-Cc-2, Lucknow

Bench: Income Tax Appellate Tribunal - Lucknow
Date: 27 February 2026
Sections engaged: 11, 12A, 139(4), 143(1), 153A, 153C, 234A, 249, 250
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 412/LKW/2024) for A.Y. 2013-14 was filed by the assessee against the order of the CIT(A)-3, Lucknow dated 16.05.2024, which had dismissed the assessee's appeal against the Assessing Officer's order under Section 143(1) dated 15.06.2020. The source preview records that the return of income was filed on 30.09.2013, and that the assessee did not file the audit report online by 30.09.2013, with the consequence that the benefit of Section 12AA was not provided and the income of the assessee was assessed at Rs. 3,82,80,430/-. The full dispositive direction of the Tribunal is not reproduced in the available source preview.

6. Rajesh Sarda,Nagpur vs Assistant Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Nagpur
Date: 24 February 2026
Sections engaged: 10(38), 132, 153A, 234A, 254(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was directed against the order of the CIT(A)-3, Nagpur dated 11.02.2022 for Assessment Year 2015-16. The order was pronounced under Section 254(1) of the Income Tax Act. The assessee also filed modified/revised grounds of appeal along with an application for their acceptance, contending that the CIT(A) ought to have deleted the addition made as the procedure was in complete violation of settled propositions of law. The full substantive findings and dispositive direction of the Tribunal are not reproduced in the available source preview.

7. Nitesh Agarwal,Agra vs Income Tax Officer-2(1)(3), Agra

Bench: Income Tax Appellate Tribunal - Agra
Date: 20 February 2026
Sections engaged: 133, 144, 147, 148, 151, 178, 234A, 234B, 250(6), 50C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 501/AGR/2025) for Assessment Year 2012-13 was filed against the order of the CIT(A) dated 30th September 2025. The assessee raised grounds, inter alia, that the CIT(A) while passing an ex-parte order ought to have considered the merits of the case; that an appellate order that does not effectively dispose of the grounds raised by the appellant is in infraction of Section 250(6) and is therefore illegal, invalid, and vitiated; that the appellant denied liability to be assessed in terms of the notice dated 30.03.2019 purportedly issued under Section 148; and that no notice under Section 178 was served on the appellant. The full dispositive direction of the Tribunal is not reproduced in the available source preview.

8. Nagpur District Shala Karmachari vs Income Tax Officer Ward 4 (4), Nagpur

Bench: Income Tax Appellate Tribunal - Nagpur
Date: 19 February 2026
Sections engaged: 234A, 80P(2)(a), 80P(2)(i)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals (ITA Nos. 774 & 775/NAG/2025) covered Assessment Years 2018-19 and 2020-21. The assessee is a credit co-operative society registered under the Maharashtra Co-operative Society Act, engaged in providing credit facilities to its members; it filed its return of income on 30.10.2018 declaring total income at Nil after claiming deduction under Section 80P(2)(a)(i). The Assessing Officer, following the decisions of the Karnataka High Court in the cases of PCIT vs. The Totagars Co-operative Sale and Guttigedarara Credit Cooperative Society Ltd. vs. ITO reported in (2015) 377 ITR 464 (Karn), rejected the claim of deduction under Section 80P on the ground that the assessee had earned interest by way of investment of funds in banks. The full dispositive direction of the Tribunal is not reproduced in the available source preview.

9. Hotel Selection Grand,Tadepalligudem vs Income Tax Officer, Ward-1

Bench: Income Tax Appellate Tribunal - Vizag
Date: 18 February 2026
Sections engaged: 133A, 142(1), 142A, 147, 148, 148A, 148A(b), 149(1), 149(1)(b), 234A, 69
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (I.T.A. No. 741/VIZ/2025) for Assessment Year 2016-17 was filed by the assessee firm against the order of the Commissioner of Income Tax (Appeals), Visakhapatnam-3 dated 24.10.2025, which arose from the order passed by the Assessing Officer under Section 147 read with Section 144 of the Income Tax Act, 1961 dated 06.01.2025. The appeal thus involves a reassessment proceeding in which the validity of the reopening and consequential provisions, including those relating to limitation and show-cause requirements, were among the matters in issue. The full substantive findings and dispositive direction of the Tribunal are not reproduced in the available source preview.

10. M/S Thdc India Limited vs PCIT, Dehradun, Dehradun

Bench: Income Tax Appellate Tribunal - Dehradun
Date: 24 December 2025
Sections engaged: 234A, 234B, 251(1)(a)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 69/DDN/2024) for Assessment Year 2020-21 was filed against the order dated 19.03.2024 of the CIT(A), National Faceless Appeal Centre, Delhi in Appeal No. NFAC/2019-20/10183461, which arose from the assessment order dated 27.09.2022. The assessee company is engaged in the business of generation and supply of hydro power as well as wind power. The source preview indicates the appeal was heard through virtual mode and the sections engaged are focused on interest charges and the scope of appellate powers. The full substantive findings and dispositive direction of the Tribunal are not reproduced in the available source preview.

11. Dsm Shared Services India Private vs DCIT., Circle 8(1), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 12 December 2025
Sections engaged: 234A, 271A, 273B, 92D
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 1358/Hyd/2024) pertains to Assessment Year 2021-2022. The source preview lists several comparable entities in what appears to be a transfer-pricing or documentation-related context, and reproduces portions of statutory sub-sections. The sections engaged indicate that questions of maintenance of documents or information under Section 92D, penalty provisions, and interest provisions including Section 234A were all in play. The full substantive findings and dispositive direction of the Tribunal are not reproduced in the available source preview.

12. M/S. Tega Industries Limited,Kolkata vs D.C.I.T., Circle - 11(1), Kolkata

Bench: Income Tax Appellate Tribunal - Kolkata
Date: 11 December 2025
Sections engaged: 135(5), 144C(1), 234A, 234B, 80, 80G, 92C(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (I.T.A. No. 1875/KOL/2024) for Assessment Year 2020-21 was filed against an assessment order dated 24.07.2024 passed under Section 143(3) read with Sections 144C(13) and 144B, which was made pursuant to the directions of Dispute Resolution Panel-2, New Delhi under Section 144C(5) dated 11.06.2024. The source preview records certain expense items (expenses for generation of steam, depreciation on turbine, electricity duty) consistent with an industrial or power-generation entity. The engagement of Section 92C(2) alongside Section 234A and 234B indicates the dispute involved transfer-pricing adjustments with consequential interest implications. The full dispositive direction of the Tribunal is not reproduced in the available source preview.

Patterns across these 12 rulings

Section 234A as a consequential charge in varied disputes. Across all twelve cases, Section 234A appears not as the primary ground of contest but as a consequential provision engaged alongside the substantive issues — reassessment validity, deduction claims, transfer-pricing adjustments, and penalty proceedings. This pattern confirms that interest under Section 234A is routinely flagged in ITAT proceedings even when the central dispute lies elsewhere.
Reassessment proceedings frequently co-engage Section 234A. Cases 1, 4, 7, and 9 all involve Section 147 and/or Section 148 alongside Section 234A, reflecting a recurring pattern where the validity of reassessment notices is contested simultaneously with the interest liability that flows from the reassessment outcome.
Deduction and exemption disputes with interest consequences. Cases 2, 5, and 8 involve disputes over exemptions or deductions (Sections 11, 12A, and 80P respectively) where the denial of the claimed benefit would generate or alter Section 234A interest exposure, illustrating how deduction litigation carries an embedded interest dimension.
Transfer-pricing and faceless assessment proceedings. Cases 10, 11, and 12 involve either the National Faceless Assessment/Appeal Centre or transfer-pricing provisions, and all three co-engage Section 234A and/or Section 234B. This suggests that large-case and TP-adjacent assessments routinely carry interest charges as part of the demand crystallised at the assessment stage.
Outcome data uniformly absent in source previews. All twelve cases carry the disposition "Outcome not specified in source," indicating that the available text previews capture only the procedural and factual recitals of the orders without reproducing the final operative directions. Researchers requiring the dispositive outcome must access the full text of each judgment from the source portal.

How to use this compilation

This compilation is structured as a rapid-reference index, not a substitute for reading the full judgment. Each entry records only the identity fields and such procedural or factual detail as appears in the source text preview. For every case where the dispositive outcome is material to a research question — for instance, whether the Tribunal upheld, deleted, or remanded a Section 234A charge — the researcher should retrieve the complete order text from indiankanoon.org or the official ITAT portal and read the operative paragraph in full. Users should also check whether any further appeal to the High Court or Supreme Court has been filed or admitted, and whether any interim stay of the demand has been granted, as none of that information is captured in this index.

When using these rulings to map the law, researchers should note that Section 234A questions frequently turn on case-specific facts such as the exact date of filing of the return, the amount of advance tax paid, and whether any extension of the due date was granted by the CBDT. A ruling in which the Tribunal directed deletion of Section 234A interest in one factual matrix may not be precedentially relevant if the underlying filing timeline or tax computation differs. Cross-referencing with CBDT notifications and circulars that extend or modify return-filing due dates for particular assessment years is therefore an essential step in any substantive research task.

Finally, researchers should verify the current status of each ITA number cited in the source previews (where available) by checking ITAT cause-lists and order registers. ITAT orders are subject to rectification under Section 254(2) and can be appealed to the High Court under Section 260A, and such subsequent proceedings could affect the precedential value of any ruling listed here.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 234A Interest Charges: 12 Recent ITAT Rulings (2025–2026)