Held that as per provisions of section 234C, interest is levied either on failure to pay advance tax by assessee or on shortfall in payment of advance tax as compared to tax due on returned income. Where assessee-trust at relevant time of deposit of advance tax had NIL taxable income, there was no liability to deposit any advance tax. Therefore, no default could be attributed to assessee for non-deposit of advance tax while estimating its income and no interest would be chargeable under section 234C of the Act. (AY. 2011-12 to 2014-15)
ACIT v. Navajibhai Ratan Trust (2022) 213 DTR 25 / 217 TTJ 137 / 140 taxmann.com 157 (Mum)(Trib)
S. 234C : Interest-Deferment of advance tax-Nil taxable income-No liability to deposit advance tax-Not liable to pay advance tax on estimated income. [S. 11]