NR was liable to pay sec. 234B interest even if Indian payer failed to withhold sum from payment mad

IT : Where non-resident assessee accepted its liability to be taxed in India at first appellate stage, all consequences under Act including liability to pay interest under section 234 would follow; assessee could not be permitted to shift responsibility to Indian payers for not deducting tax at source from remittances, after leading them to believe that no tax was deductible