Section 234C interest not applies to shortfall in advance tax payment on windfall gain/unexpected income

Hamilton Industries Pvt. Ltd. Vs ITO (ITAT Mumbai)

Whether Commissioner of Income Tax (A) erred in conferring the interest of Rs.12,31,304/- under section 234C of the Income tax Act, 1961 without appreciating that the book profit includes capital gain income which arose in 4h quarter therefore the liability to pay advance tax arise only on 15.03 .2018 & 30.03.2018?

Then provisions of S. 234C (1) regarding payment of interest shall not apply to any shortfall in the payment of the advance tax due on the ret

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