This compilation indexes eleven rulings — spanning ITAT benches across Bangalore, Jabalpur, Cochin, Nagpur, Kolkata, Delhi, Agra, and Mumbai, as well as the Madras and Uttarakhand High Courts — in which Section 234C of the Income Tax Act, 1961 was a cited provision. The rulings range from January 2018 to June 2026 and arise in a variety of factual contexts, including disallowances, transfer pricing, advance tax computation, and interest waiver writ petitions. This index is intended for use by in-house tax teams, Big-4 associates, and law firm researchers who need a structured starting point for primary-source research.

Research index only. This page is a structured case-law reference compiled for research purposes. Nothing on this page constitutes legal or tax advice. Readers must verify all information against the full text of the relevant judgment and consult qualified advisors before acting on any matter.

The statutory framework in one paragraph

Section 234C of the Income Tax Act, 1961 imposes mandatory interest on an assessee who fails to pay advance tax instalments on time or pays instalments that are short of the prescribed percentages of the assessed tax liability. The section prescribes interest at the rate of one per cent per month (or part of a month) on the amount of the shortfall, calculated separately for each instalment due date — 15 June, 15 September, 15 December, and 15 March of the relevant financial year. Certain exceptions exist in the statute, including where the shortfall arises on account of an underestimate or failure to estimate the amount of capital gains or income under the head "Profits and gains of business or profession" accruing after the due date of the last instalment, provided the assessee pays the full tax on such income by 31 March of the financial year. The CBDT has also issued circulars prescribing conditions under which the Chief Commissioner or Director General of Income Tax may waive or reduce interest charged under Section 234C; the exercise of that power has been the subject of several writ petitions in various High Courts.

The 11 rulings

1. Shankara Building Products vs DCIT, Circle-6(1)(1), Bengaluru

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 11 June 2026
Sections engaged: 10(34), 142(1), 143(2), 143(3), 14A, 234A, 234B, 234C, 250
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 291/Bang/2026) was filed by the assessee against an order passed under section 250 for assessment year 2020-21. Per the source preview, the assessee's solitary grievance was against a disallowance made under section 14A read with Rule 8D; the assessee is described as a retailer of home improvement and building products. Sections 234A, 234B, and 234C are cited in the proceedings but the substantive findings on those provisions are not detailed in the available source preview.

2. Supreme Tractors Private vs DCIT, Katni

Bench: Income Tax Appellate Tribunal - Jabalpur
Date: 27 February 2026
Sections engaged: 234C, 115J
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 51/JAB/2025) relates to assessment year 2016-17. Per the source preview, the Assessing Officer, while processing the Income Tax Return of the assessee, made an adjustment and computed capital gain and deemed income; the AO also computed tax accordingly. The appeal was filed against that adjustment, and both Section 234C and Section 115J are cited as engaged provisions, though the specific findings on each provision are not detailed in the available source preview.

3. Suntec Business Solutions Private vs ACIT, Circle 1(1), Trivandrum

Bench: Income Tax Appellate Tribunal - Cochin
Date: 30 September 2024
Sections engaged: 144C, 115J, 234C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals (IT(TP)A No. 01/Coch/2021 for AY 2016-17 and IT(TP)A No. 04/Coch/2022 for AY 2017-18) are transfer pricing matters. Per the source preview, the Tribunal directed the TPO/AO to exclude certain named companies from the comparables set used for benchmarking. Section 234C is listed as a cited provision in the proceedings; the source preview does not contain specific findings on the Section 234C ground.

4. Stellar Refractories Private Limited vs Deputy Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Nagpur
Date: 6 June 2024
Sections engaged: 36(1)(va), 234C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 420/Nag./2022) was filed against the order of the CIT(A), National Faceless Appeal Centre, Delhi, for assessment year 2020-21. Per the source preview, the grounds of appeal include matters relating to the Employee Provident Fund Act and the Employee Provident Fund Scheme, 1952, with Section 36(1)(va) and Section 234C both cited as engaged provisions. The source preview does not contain specific findings on the Section 234C ground.

5. M/S Rupa & Company Limited, Kolkata vs DCIT, Cen. Cir. -2(3), Kolkata

Bench: Income Tax Appellate Tribunal - Kolkata
Date: 27 March 2023
Sections engaged: 244A, 234B, 234C
Outcome: Outcome not specified in source
Procedural / substantive ground: The three appeals (I.T.(S.S.)A. Nos. 9, 10 & 11/Kol/2022) cover assessment years 2012-13, 2013-14, and 2014-15 and were directed against separate orders passed under section 250 by the CIT(A)-20, Kolkata, dated 10.01.2022. Sections 244A, 234B, and 234C are cited as engaged provisions; the source preview references figures for each of the three assessment years but does not contain detailed substantive findings on any individual provision.

6. Expeditors International Of vs ACIT (International Taxation), New

Bench: Income Tax Appellate Tribunal - Delhi
Date: 5 January 2022
Sections engaged: 234C
Outcome: Outcome not specified in source
Procedural / substantive ground: This is a bundle of five appeals (ITA Nos. 1904 & 5851/Del/2017, 6827/Del/2018, 4778/Del/2019, and 180/Del/2021) filed by the assessee, covering assessment years 2012-13, 2013-14, 2014-15, 2015-16, and 2017-18. Per the source preview, the appeals were heard through video conferencing and Section 234C is the sole cited provision. The source preview does not contain substantive findings on the grounds argued.

7. Aara Agro Pvt. Ltd., Agra vs Dy.CIT., Circle-2(1)(1), Agra

Bench: Income Tax Appellate Tribunal - Agra
Date: 23 November 2021
Sections engaged: 115J, 234B, 234C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 54/AGR/2021) relates to assessment year 2018-19. Per the source preview, the appellant earned income from capital gains and an advance tax liability arose in connection therewith; a preliminary issue regarding condonation of delay in filing the appeal before the CIT(A) is also referenced in the preview. Sections 115J, 234B, and 234C are cited as engaged provisions; the source preview does not contain specific findings on any individual provision.

8. Edenred Pte Ltd, Mumbai vs DCIT (It) 2(2)(1), Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 20 July 2020
Sections engaged: 195, 234B, 234C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals (ITA No. 1718/MUM/2014 for AY 2010-11, ITA No. 254/MUM/2015 for AY 2011-12, and ITA No. 507/MUM/2016 for AY 2012-13) involve the assessee, a foreign company, with the proceedings involving questions of international taxation. Per the source preview, the order references figures relating to IDC charges, management service fees, and referral fees across multiple entities. Sections 195, 234B, and 234C are cited as engaged provisions; the source preview does not contain specific findings on the Section 234C ground.

9. Tvl. Sanmac Motor Finance Ltd vs Chief Commissioner Of Income Tax

Bench: Madras High Court
Date: 10 February 2020
Sections engaged: 234A, 234B, 234C
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (W.P. No. 12500 of 2010) was filed under Article 226 of the Constitution of India seeking a writ of certiorarified mandamus to quash an order dated 16.03.2010 passed by the Chief Commissioner of Income Tax and to direct waiver of interest under Sections 234A, 234B, and 234C of the Act. Per the source preview, the petitioner was aggrieved by the order of the first respondent rejecting its application for such waiver; the substantive findings of the High Court are not detailed in the available source preview.

10. Harish Kumar Gupta vs Chief Commissioner Income Tax And

Bench: Uttarakhand High Court
Date: 10 January 2018
Sections engaged: 234C, 132
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (Writ Petition (M/S) No. 1658 of 2013) was filed before the High Court of Uttarakhand at Nainital. Per the source preview, the petitioner had filed an income tax return declaring total income of Rs. 51,10,850/- and the Assessing Authority imposed interest of Rs. 11,02,480/- under the interest provisions of the Act; the petitioner subsequently filed an application for waiver of interest, which was rejected by the competent authority on 12.04.2013. The petitioner also filed an application for rectification under a separate provision and sought adjournment before the competent authority; Section 234C and Section 132 are cited as engaged provisions.

11. M/S.Van Oord Acz Bv vs The Chief Commissioner Of Income Tax-I

Bench: Madras High Court
Date: 3 January 2018
Sections engaged: 234B, 234C
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (W.P. No. 14165 of 2009) was filed under Article 226 of the Constitution of India seeking a writ of certiorarified mandamus to quash an order dated 09.02.2009 passed by the Chief Commissioner of Income Tax-I, Chennai, and to direct waiver of interest levied under Sections 234B and 234C of the Act. Per the source preview, the petitioner is a non-resident entity with its registered office in the Netherlands; the source preview does not detail the substantive findings of the High Court on the waiver application.

Patterns across these 11 rulings

Interest waiver writ petitions form a distinct sub-category. Three of the eleven rulings (cases 9, 10, and 11) are writ petitions before High Courts challenging orders of the Chief Commissioner of Income Tax rejecting applications for waiver of interest under Section 234C (and companion interest provisions). This reflects a recurring procedural pathway where assessees aggrieved by waiver rejections approach the High Court under Article 226.
Section 234C frequently appears alongside companion interest provisions. Across the corpus, Section 234C is rarely cited in isolation; it co-appears with Section 234B in cases 5, 7, 8, 9, and 11, and with Section 234A in cases 1, 9, and 10. This suggests that advance tax shortfall disputes tend to be raised collectively across the deferment interest provisions rather than as a standalone ground.
Section 115J / deemed income computations are a recurring co-issue. In cases 2, 3, and 7, Section 234C is cited alongside provisions relating to deemed income or minimum alternate tax-related computations (Section 115J). This pattern suggests that advance tax interest disputes in such cases often arise from the complexity of computing advance tax liability where deemed income is involved.
International taxation and non-resident assessees appear in multiple matters. Cases 6, 8, and 11 involve non-resident or foreign entities facing Section 234C exposure in the context of international taxation proceedings, indicating that the provision is actively engaged in cross-border tax disputes.
Source previews across this corpus are largely procedural. For all eleven rulings, the available source text consists substantially of cause-title pages, procedural orders, and preliminary facts. Substantive holdings on Section 234C grounds are not visible in the extracted previews, which is a limitation researchers should note when using this index as a starting point — access to the full judgment text is essential.

How to use this compilation

This index is a first-pass research tool, not a substitute for full-text judgment review. Each entry identifies the forum, bench, date, sections engaged, and outcome direction as extracted from the TaxNoticeAI structured legal corpus. Because the source previews for all eleven rulings in this compilation are largely limited to procedural and cause-title content, researchers should treat the "Sections engaged" field as a reliable flag for relevance and then retrieve the complete judgment from indiankanoon.org, the relevant High Court portal, or the ITAT e-filing portal before drawing any conclusions about the legal proposition established by the ruling.

Researchers should also verify whether any ruling listed here has been stayed, reversed, modified, or distinguished in subsequent proceedings. Appeals from ITAT orders may be pending before the relevant High Court, and writ petition orders may have been appealed to the Supreme Court. The date of order shown reflects the date of the ruling in the corpus and does not indicate the current status of the litigation.

Finally, users should cross-reference any relevant CBDT circulars and instructions on interest computation under Section 234C, including any circulars prescribing the conditions and competent authority for waiver. Administrative instructions can affect how the statutory provision is applied in practice, and such instructions may have been issued or revised after the date of the rulings listed in this compilation.

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 234C Interest on Advance Tax: 11 ITAT and HC Rulings Indexed