Following the Supreme Court ruling in the case of Bharat Commerce and Industries Ltd. Vs. Commissioner of Income-tax (230ITR733) the Delhi High Court in the case of Usha Sales Ltd. v. CIT (119TAX472) held that all liability for interest incurred under various sections of the Income tax Act, 1961 is not deductible, be it interest for failure to deduct tax, failure to pay advance tax, failure to pay tax itself etc etc. Meaning thereby that the real cost of such interest is as much as 23% after taking tax effect. It is therefore advisable to pay taxes in advance and even on additions that are disputed. In that case a separate challan may be used to pay such tax up front and the same may bear a note “ Under Protest” on top.