An assessee cannot be said to be a defaulter in payment of advance tax if he had no liability to pay any advance tax under s 208 on any of the due dates for payment of the advance tax

Emami Ltd. Vs CIT (High Court of Calcutta)- Where on the last date of the Financial Year preceding the relevant Assessment Year, the assessee had no liability to pay advance tax, he would be nevertheless asked to pay interest in terms of Section 234B and Section 234C of the Act for default in making payment of tax in advance which was physically impossible.