https://www.taxtmi.com/caselaws?id=78020 Interest under Section 234B cannot be levied on a non-resident where tax was statutorily deductible at source by the payer, because the advance-tax computation excludes income subject to TDS and the non-resident has no statutory role in deduction or collection; the Department's remedy lies against the payer defaulting in withholding. Interest under Section 234D is not retrospective and applies only from assessment year 2004-05, so it cannot be charged for earlier assessment years. On these principles, the interest demands were deleted and the Revenue's appeals failed. en-us Mon, 30 Aug 2010 00:00:00 +0530 Mon, 14 Apr 2025 13:02:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=78020 Interest under Section 234B cannot be levied on a non-resident where tax was statutorily deductible at source by the payer, because the advance-tax computation excludes income subject to TDS and the non-resident has no statutory role in deduction or collection; the Department's remedy lies against the payer defaulting in withholding. Interest under Section 234D is not retrospective and applies only from assessment year 2004-05, so it cannot be charged for earlier assessment years. On these principles, the interest demands were deleted and the Revenue's appeals failed. Case-Laws Income Tax Mon, 30 Aug 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=78020