Dismissing the appeal of the revenue the Court if payer, who was required to make payments to non-resident, had deducted tax at source, question of payment of advance tax by payee would not arise and, therefore, it would not be permissible for revenue to charge interest under section 234B. (AYs. 2005-06, 2006-07)
DIT(IT) v. Texas Instruments Incorporated (2020) 275 Taxman 614 (Kern.)(HC)
S. 234B : Interest-Advance tax-Non-Resident-Levy of interest is not liable. [S. 195]