Dismissing the appeal of the revenue the Court held that assessee being a non-resident company, entire tax was to be deducted at source on payments made by payer to it and there was no question of payment of advance tax, hence it would not be permissible for revenue to charge any interest under section 234B of the Act. (AY. 2013-14)
CIT(IT) v. ZTE Corporation (2021) 130 taxmann.com 128 (Delhi)(HC) Editorial : SLP of revenue dismissed, CIT (IT) v. ZTE Corporation (2021) 282 Taxman 304 (SC)/ Review petition dismissed,CIT (IT) v. ZTE Corporation (2024) 296 Taxman 571 (SC)
S. 234B : Interest-Advance tax-Non-Resident-Entire tax was deductible at source-Not permissible to charge interest. [S. 9(1)(1)]