The Assessing Officer computed the assessee’s book profit under S.  115JB  of the Act and charged interest thereon under S.  234B and 234C of the Act  . The CIT (A) deleted the interest  by following the judgement in Kwality Biscuits Ltd. v. CIT [2000] /243 ITR 519 (Karn) (HC)   Appellate Tribunal  referred the decision in Jt. CIT v. Rolta India Ltd. [2011)  330 ITR 470 (SC) wherein the Court held that where MAT companies defaulted in payment of advance tax in respect of tax payable under S.  115JB of the Act  it was liable to pay interest under S. 234B and 234C of the Act. However, according to the  Appellate Tribunal, the judgment of the Supreme Court in Rolta India Ltd. (supra) was delivered subsequently which would not discredit the bona fide reason entertained by the assessee in not depositing the advance tax on MAT in view of the prevailing judgment of the Karnataka High Court in Kwality Biscuits Ltd. (supra) which was then holding the field. Accordingly  the Appellate  Tribunal held that there was no reason to interfere with the finding of the first appellate authority, albeit on a different ground.  On appeal by the revenue the Court held that  in Star India (P.) Ltd. v. CCE [2006] 280 ITR 321 (SC) , considered the question of payment of interest in default of payment of the tax in the context of service tax it was held that liability to pay interest would only arise on default and is really in the nature of a quasi punishment  which is followed  in CIT v. JSW Energy Ltd. [2015] 379 ITR 36 (Bom.)(HC)  .Accordingly the High Court up held the order of the Appellate Tribunal by observing that   when there was   no liability to  pay advance tax on book profits as per the ruling of High Court  and subsequent over-ruling of  High Court decision by Supreme Court , interest not Chargeable.   (AY.2004-05, 2005-06)