In Brief
The Supreme Court resolved whether non-resident and foreign company assessees could reduce advance tax liability by the amount of income-tax deductible at source, when the payer failed to actually deduct it. The Court held that prior to April 1, 2012, Section 209(1)(d) permitted such reduction, making assessees non-liable for interest under Section 234B when tax was deductible but not deducted. The proviso inserted by Finance Act, 2012 reversed this position for financial years 2012-13 onward. The judgment relied on subsequent legislation as an interpretive tool to clarify the earlier provision's ambiguity.",
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