The Tax Publishers2020 TaxPub(DT) 4109 (Karn-HC) : (2021) 436 ITR 0641 : (2021) 276 TAXMAN 0211

INCOME TAX ACT, 1961

Section 34B

No interest under section 234B accrues or is leviable in the case of the assessee which is a foreign company and no advance tax is liable to be paid by it as its income is liable to tax deduction at source following the decision held in case of DIT v. M/s. Texas Instruments Incorporated 2020 TaxPub(DT) 3980 (Karn-HC).

Interest under section 234B - Chargeability - Income subject to TDS -

Revenue filed appeal against the order of Tribunal holding that no interest under section 234B accrues or is leviable in the case of the assessee which is a foreign company and no advance tax is liable to be paid by it as its income is liable to tax deduction at source. Held: This substantial question of law had already been answered against the revenue in case of Texas Instruments Incorporated 2020 TaxPub(DT) 3980 (Karn-HC). Following the same, the issue was decided against the revenue.

Followed:DIT v. Texas Instruments Incorporated 2020 TaxPub(DT) 3980 (Karn-HC).

REFERRED :

FAVOUR : In favour of assessee.

A.Y. : 2007-08


INCOME TAX ACT, 1961

Section 115A

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