PR. CIT-I INTERNATIONAL TAXATION vs. ANIMAL PLANET (ASIA) LLC
What did the High Court hold?
The Delhi High Court followed its prior ruling in Director of Income Tax v. Jacabs Civil Incorporated & Mitsubishi Corporation. The court held that the Revenue's appeal on the issue of interest under Section 234B was covered by this precedent.
What were the facts?
The Revenue appealed against the ITAT's decision concerning interest payable under Section 234B of the Income Tax Act. The Revenue acknowledged that the issue was covered by a previous High Court decision.
What were the issues?
Whether interest under Section 234B of the Income Tax Act is payable in the given circumstances, considering a prior High Court judgment.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Cases cited in this judgment(1)Show listHide list
Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.
- DIT v. Jacabs Civil Incorporated/ Mitsubhishi Corporation115 citing330 ITR 578 · 2011 · HC
$~ * IN THE HIGH COURT OF DELHI AT NEW DELHI 18. +
ITA 862/2015
PR. CIT-I INTERNATIONAL TAXATION ..... Appellant Through: Mr. Rahul Chaudhary, Senior Standing counsel.
versus
ANIMAL PLANET (ASIA) LLC
..... Respondent
AND 19. +
ITA 863/2015
THE PR. COMMISSIONER OF INCOME TAX-1 ..... Appellant Through: Mr. Rahul Chaudhary, Senior Standing counsel.
versus
ANIMAL PLANET (ASIA) LLC
..... Respondent
CORAM: JUSTICE S. MURALIDHAR JUSTICE VIBHU BAKHRU
O R D E R %
17.11.2015
CM No. 26987/2015 (for exemption) in ITA 862/2015 1. Exemption allowed subject to all just exceptions.
The application is disposed of. ITA Nos. 862/2015 & 863/2015
Page 1 of 2 This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 04/04/2026 at 21:49:43
ITA Nos. 862 of 2015 & 863 of 2015 3. It is not disputed by learned counsel for the Revenue that questions urged by it concerning interest payable under Section 234B of the Income Tax Act, 1961 stands covered against the Revenue by the decision of this Court in Director of Income Tax v. Jacabs Civil Incorporated & Mitsubishi Corporation [2010] 330 ITR 578 (Del). It is stated that the said decision has been challenged by the Revenue by way of a Special Leave Petition which is pending in the Supreme Court.
Following the aforementioned decision of this Court, these appeals are dismissed.
S. MURALIDHAR, J
VIBHU BAKHRU, J NOVEMBER 17, 2015 dn
ITA Nos. 862/2015 & 863/2015
Page 2 of 2 This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 04/04/2026 at 21:49:43
Similar judgments
Other orders that rely on the same authority or decide the same section.
- Director of Income Tax-II vs British Airways PlcDelhi5 Mar 2015Dismissed
Also relies on DIT v. Jacabs Civil Incorporated/ Mitsubhishi Corporation
The High Court held that the assessee was not liable to pay interest under Section 234B. This decision was based on previous rulings by the same court in similar cases concerning foreign companies and the applicability o...
- Director of Income Tax vs British Airways PlcDelhi5 Mar 2015Dismissed
Also relies on DIT v. Jacabs Civil Incorporated/ Mitsubhishi Corporation
The High Court held that the assessee was not liable to pay interest under Section 234B. This decision was based on previous rulings by the same court concerning similar issues and the applicability of the Double Taxatio...
- Director of Income Tax International… vs Ge Packaged Power IncDelhi12 Jan 2015Dismissed
Also relies on DIT v. Jacabs Civil Incorporated/ Mitsubhishi Corporation
The High Court held that the primary liability to deduct tax at source under Section 195 lies with the payer. The payer is considered an assessee in default if they fail to discharge this obligation. Therefore, no intere...
- Agence Frances Press vs Asst. Dirctor of Income TaxDelhi23 Mar 2015Allowed
Also relies on DIT v. Jacabs Civil Incorporated/ Mitsubhishi Corporation
The High Court held that interest under Section 234B is not leviable on the assessee. The primary liability to deduct tax at source under Section 195 lies with the payer, who may be considered an assessee-in-default if t...
- DIT-I, International Taxation vs Alcatel Lucent Usa, IncDelhi7 Nov 2013Allowed
Also relies on DIT v. Jacabs Civil Incorporated/ Mitsubhishi Corporation
The Delhi High Court held that the assessee was liable to pay interest under Section 234B. The court found that the assessee had the use of money that should have been paid as advance tax and that equitable consideration...
More judgments on Section 234B
- Vikas Ashokkumar Masand, Ahmedabad vs The Dy. Commissioner of Income Tax…ITA 3130/AHD/2026[A.Y. 2017-18]Status: Disposed19 Oct 2026
- Shalin Jayantbhai Desai, Vadodara vs ACIT, Circle-4(2), Vadodara Present…ITA 2569/AHD/2026[2010-11]Status: Disposed19 Oct 2026AY 2010-11
- Sarvjeet Singh Through Legal Heir Manjit… vs ITO Ward 1(1), AlwarITA 355/JPR/2025[2013-14]Status: Disposed16 Oct 2026AY 2013-14
- Parthasaradhi Mutually Aided Co-Operative… vs Income-Tax Officer, Ward-17(1), HyderabadITA 2322/HYD/2026[AY 2016-17]Status: Disposed16 Oct 2026
- Cornerstone Ondemand International Limited… vs Assistant Commissioner of Income Tax…ITA 2128/MUM/2025[2022-23]Status: Disposed16 Oct 2026AY 2022-23
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