Section 234B, read with sections 195 and 209, of the Income-tax Act, 1961

The High Court of Delhi where assesses were non-resident companies, entire tax was to be deducted at source on payments made by payer to it and there was no question of payment of advance tax by assesses; therefore, revenue could not charge any interest under section 234B from assesses. The Supreme Court of India held that certification of incorporation etc., are not sufficient for purpose of identification of Subscription Company when there is material to show that subscriber was a paper company and not a genuine investor.