https://www.taxtmi.com/caselaws?id=5587 The Supreme Court ruled in favor of the non-resident shippers, holding that payments made under section 172(4) of the Income-tax Act should be treated as advance tax. The Court emphasized that section 172(7) allows for regular assessment, treating earlier payments as advances of tax for the assessment year. The Court rejected the High Court's distinction between "advance tax" and "payment in advance of the tax," stating that the legal fiction in section 172(7) deems the payments as advance tax. Consequently, the Court reversed the High Court's judgment, allowing the shippers' appeals and entitling them to interest on excess payments upon regular assessment. en-us Thu, 03 Apr 1997 00:00:00 +0530 Mon, 20 Jul 2026 12:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5587 The Supreme Court ruled in favor of the non-resident shippers, holding that payments made under section 172(4) of the Income-tax Act should be treated as advance tax. The Court emphasized that section 172(7) allows for regular assessment, treating earlier payments as advances of tax for the assessment year. The Court rejected the High Court's distinction between "advance tax" and "payment in advance of the tax," stating that the legal fiction in section 172(7) deems the payments as advance tax. Consequently, the Court reversed the High Court's judgment, allowing the shippers' appeals and entitling them to interest on excess payments upon regular assessment. Case-Laws Income Tax Thu, 03 Apr 1997 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5587