Sec. 234C of Income Tax Act, 1961 – Advance Tax – The appellant had a dispute with M/s. HSBC. It went up to the Supreme Court of India in appeal. On July 15, 2013, same was dismissed and on August 5, 2013 directed the Registry of the Supreme Court to release the money deposited by M/s. HSBC in favour of the appellant. Accordingly, the appellant received a sum of Rs. 102,59,36,115, which resulted in a profit of Rs. 56,01,36,301 for the financial year 2013-14. The same was deposited in the appellant's account on October 3, 2013. In the meantime, on August 14, 2013, M/s. HSBC filed a review petition against the judgment of Supreme Court of directing the release of money to the appellant herein which was dismissed on December 3, 2013. The appellant on the ground that the matter was pending before the Supreme Court, paid the required advance tax for the assessment year 2014-15 only in the third quarter. However, the authorities on the ground that the advance tax was not paid in the first two quarters, charged interest under section 234C of the Act, 1961, amounting to Rs. 20,21,466. The appellant challenged the same before the respondent seeking waiver of complete interest charged under section 234C of the Act but it was unsuccessful. Thereafter, writ petition of the appellant came to be dismissed.

The appeal filed came to be dismissed by High Court holding that:– In the absence of any interim order, mere filing of a review petition before the hon'ble Supreme Court is no ground for non-payment of advance tax – CANBANK FINANCIAL SERVICES LTD. [2020] 423 ITR 113 (KARN)