Assistant Director Of Income Tax vs White Industries Australia Ltd *

Whether interest under section 234B of the Income-tax Act, 1961 is leviable on a non-resident assessee when tax was deductible at source under section 195 on payments received, even if not actually deducted? --- Held, No. Whether the reassessment proceedings under section 147 were validly initiated? --- Held, Yes (as the assessee's appeals on this issue were dismissed for non-prosecution). Whether interest under section 220(2) is chargeable? --- Held, matter restored to AO/CIT(A) for determination as per CBDT Circular No. 334.