IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION NOTICE OF MOTION NO. 3533 OF 2007 IN INCOME TAX APPEAL (L) NO. 1796 OF 2007 The Director of Income tax (international Taxation) .... Appellant versus M/s. Morgan Guarantee International Finance Corporation )........ Respondant. Mr. P.A. Vyas for the Appellant Mr. A.K. Jasani for the Respondents. CORAM: SWATANTER KUMAR, C.J., & A.P. DESHPANDE, J. DATED: 16TH JULY 2008. P.C.: 1. This is an application for condonation of delay. The other side has no objection. Consequently the Notice of Motion is made absolute in terms of prayer clause (a). Delay is condoned. 2. With the consent of parties, the appeal is taken up for final hearing. 3. We have heard the learned counsel appearing for the parties. The only question i.e. sought to be raised in the present appeal, while challenging the order of Income Tax Appellate Tribunal dated 13th September 2006 is that the interest under section 234B and 234C of the Income Tax Act are not liable to pay by the assessee because they are not liable to pay advance tax interest. 4. We have perused the judgment of the Tribunal, who relied upon two earlier judgments including that of the Special Bench of the Tribunal in case of Sedco Forex International Vs. DCIT reported in 72 ITD 415 and in case of Motorola Inc. 95 ITD 269(SB)(Del). The view taken by the Tribunal in case of Sedco Forex International was also affirmed by the Bench of High Court in 264 ITR page 320. No question of law, much less substantial question of law arises in the present case. We see no reason to take a different view. Hence appeal is dismissed. CHIEF JUSTICE A.P. DESHPANDE, J.