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2013 (7) TMI 733 - HC - Income TaxInterest u/s 234B - Order u/s 154 - Interest on non resident - Tribunal held that interest u/s 234B cannot be invoked by order u/s 154 - Held that:- proceedings were taken under section 154 of the Income-tax Act on the ground that since the advance tax paid was less than 90 per cent., interest under section 234B of the Income-tax Act was leviable on the assessee - when there was 100 per cent. deduction of tax at source and there being no liability to pay any advance tax, interest under section 234B could not be charged on the assessee - when the entire tax is deducted at source and the consequence of non-deduction is given under section 201, the question of levy of interest under section 234B on the assessee did not arise - Following decision of Director of Income-tax v. Jacabs Civil Incorporated [2010 (8) TMI 37 - DELHI HIGH COURT] and CIT v. Madras Fertilizers Ltd. [1983 (9) TMI 74 - MADRAS High Court] - Decided against the Revenue.
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