Section 234B interest cannot be levied when entire income is subject to TDS

NGC Network Asia LLC Vs DDIT- International Tax (ITAT Mumbai) One of The ground raised by the assessee is with regard to charging of interest u/s.234B of the Act. We find that assessee is a non-resident whose entire income is subject to deduction of tax at source u/s.195 of the Act. Accordingly, the assessee had pleaded that it is not liable to pay advance tax and consequently not liable to pay any interest u/s.234B of the Act which was not appreciated by the ld. AO and the ld. CIT(A). We find that the issue in dispute is squarely addressed by the decision of the Hon’ble Jurisdictional H...