No Section 234B Interest for Advance Tax Shortfall due to Retrospective Amendment

DCIT Vs Reliance Industries Ltd. (ITAT Mumbai) The issue under consideration is whether the interest u/s 234B for less payment of advance tax will be levied on account of additions made to total income, consequent to retrospective amendment? In the present case, additions was made to book profits computed u/s 115JB, towards deduction claimed on eligible profit u/s 80HHC of the Act, on the basis of retrospective amendment to Section 115JB of the Act, by omitting clause (iv) to (vii) to explanation 1 by the Finance Act, 2011 with effect from 01/04/2005. Further, at the time of payment of advance...