For the Assessment Year 2021-22 DD Ltd. paid Tax @ 15% on its book profit computed under section 115 JB. During the assessment proceedings the Assessing officer wants to charge interest under Section 234A and 234B as the

The issue in this case is whether interest is charged under section 234B and 234C, if the Company is paying tax on the basis of book profit under section 115JB of the Income-tax Act, 1961. Though 115JB is a self-contained section pertaining to Minimum Alternate Tax 'MAT' provision but sub-section (5) of section 115JB specifies that save as otherwise provided in this section, all other provisions of this Act shall apply to every assessee, being a company mentioned in that section. Therefore, except for substitution of tax payable and the manner of computation of book profits, all the provisions relating to charge, definitions, recoveries, payment, assessment, etc., would apply in respect of the provisions of this Section. Accordingly, the payment of Advance Tax would be required. Further, according to section 207 of the Income-tax Act, 1961, tax shall be payable in advance during any financial year in accordance with the provisions of section 208 to 2019. As book profit is deemed to be total income, therefore as per the provisions of section 207, advance tax is required to be paid. If a Company defaults in payment of advance tax under section 115JB, it would be liable to pay interest under section 234B and 234C. From the above analysis, it is concluded that Assessing Officer is right in charging interest under section 234B and 234C.