Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
Interest under section 234C cannot be levied for advance tax instalments falling due before a newly set up business begins operations, because income from that source was not yet capable of estimation on those dates. Reading section 234C with the proviso to section 3 and clause (c) of the proviso to section 234C(1), the Tribunal held that the assessee's business, which commenced on 17.10.2019, created no obligation to anticipate or pay business advance tax for the June and September instalments. The earlier instalments were excluded, and the interest was directed to be recomputed only for the period after commencement of business.
Interest under section 234C cannot be levied for advance tax instalments falling due before a newly set up business begins operations, because income from that source was not yet capable of estimation on those dates. Reading section 234C with the proviso to section 3 and clause (c) of the proviso to section 234C(1), the Tribunal held that the assessee's business, which commenced on 17.10.2019, created no obligation to anticipate or pay business advance tax for the June and September instalments. The earlier instalments were excluded, and the interest was directed to be recomputed only for the period after commencement of business.
Note: It is a system-generated summary and is for quick reference only.