The ITAT held that the appellant was not liable to pay interest...

The ITAT held that the appellant was not liable to pay interest under section 234B for failure to pay advance tax, as the liability arose from a retrospective amendment relating to transfer pricing provisions introduced after the return was filed. Since the appellant could not have anticipated the amendment when determining advance tax liability, they cannot be deemed a defaulter. The Tribunal noted that the CIT(A) erred in upholding the interest charge without considering the retrospective nature of the amendment and the consequent absence of a prior obligation. Accordingly, the appeal was allowed, and the interest under section 234B was set aside.