Section 234B not applicable if no liability for payment of advance tax

Amadeus IT Group SA Vs DCIT (ITAT Delhi) AR for the taxpayer contended that in the absence of any liability for payment of advance tax since tax is deductible at source on the income of the taxpayer held liable to tax in India, the levy of interest u/s 234B is not warranted.  Provisions contained below section 209(1)(d) of the Act introduced by Finance Act, 2012 w.e.f 01.04.2012 would apply only in a situation where persons responsible for tax has paid or credited such income without deduction of tax. In the instant case, since the income has been received by the taxpayer after deduction of t...