JUDGMENT Sabhahit, J.—This appeal is filed by the assessee being aggrieved by the Income Tax Appellate Tribunal, Bangalore Bench B (hereinafter called the ITAT) in ITA No. 184/Bang/2003 for the assessment year 1999-2000 wherein the appeal filed by the revenue was dismissed. The material facts leading up to this appeal are as follows: The assessee filed its return of income for the assessment year 1999-2000 on 31-12-1999. The assessment was completed under section 143(3) on 19-3-2000. The assessing officer while making the assessment, gave direction for charging of interest under section 234B and 234C of the Income Tax Act, 1961 (hereinafter called the Act) and determined the income under section 115JA of the Act. Being aggrieved by the income under section 234B and 234C of the Act, the assessee filed an appeal before the Commissioner (Appeals)-VI, Banglore. The first appellate authority dismissed the appeal by holding that decision in Kwality Biscuits Ltd. Vs. Commissioner of Income Tax, (2000) 243 ITR 519 KAR is not helpful to the assessee in this case and the assessing officer was justified in imposing interest under sections 234B and 234C of the Act in view of the provisions of 115JA of the Act. Being aggrieved by the said order, the assessee preferred an appeal before the ITAT. The ITAT dismissed the appeal confirming the order passed by the first appellate authority and holding that imposition of interest under sections 234B and 234C of the Act is justified and the decision in Kwality Biscuits was not helpful to the present case as the said decision was in respect of income computed under section 115J of the Act. Being aggrieved by the said order passed by the ITAT, this appeal is filed by the assessee. 2. This appeal was admitted on 6-12-2006 for consideration of the following substantial questions of law raised in this appeal: (a) Whether on the facts and circumstances of the case, the Tribunal ought to have applied the decision of the Karnataka High Court in Kwality Biscuits case, ( ) 243 ITR 519 (Karn)? (b) Whether the Tribunal was right in holding that the decision of the Hon'ble Karnataka High Court in Kwality Biscuits case has not become final and hence not binding on it? (b) Whether the Tribunal was right in holding that the decision of the Hon'ble Karnataka High Court in Kwality Biscuits case has not become final and hence not binding on it? (c) Whether the Tribunal was right in holding that in view of section 115A(4) wordings, the decision of the Karnataka High Court is not applicable to the facts of the appellants case? (d) Whether on the facts and circumstances of the case, the Tribunal was right in not answering the question of limitation specifically raised in Ground No. 9 of the Grounds of Appeal? (e) Whether on the facts and circumstances of the case, the Tribunal ought to have followed the decision of the Karnataka High Court in Kwality Biscuits case and also the earlier decision of the same Tribunal dated 12-12-2003 in Jt. CIT v. M/s. Bharatiya Reserve Bank Note Mudran Ltd's case and in the appellants own case for the same year rendered under section 145 read with section 143(1) order? (f) On the facts and circumstances for the case, whether the Tribunal was right in not rectifying its order under section 254(2) as prayed for by the appellant? 3. We have heard learned counsel appearing for the appellant and learned counsel appearing for the respondent. 4. The learned counsel appearing for the appellant-assessee submitted that though the substantial questions of law No. (a) to (f) have been framed, the substantial question of law that arise for determination is 'whether the authority were justified in not applying the decision of this court in Kwality Biscuits ( ) 243 ITR 519 (Karn), However, the learned counsel submitted that since the assessment is made under section 115JA, the computation of income will be made only at the end of the year and therefore, the question of deducting payment of tax in advance would not arise and therefore, the authorities below ought to have relied upon the decision in Kwality Biscuits rendered by this court. 5. 5. The learned counsel appearing for the respondent submitted that the question of law has been considered and answered by the Supreme Court by holding that when the assessment is made under section 115A of the Act, in view of the provisions of section 115JA(4) of the Act, the provisions of sections 243B and 234C of the Act would be applicable and the decision in Kwality Biscuits was confined to the judgment where the order of assessment was made under section 115J of the Act. In support of his contention, he has relied upon the recent decision of the Supreme Court in Jt. Commissioner of Income Tax, Mumbai Vs. Rolta India Ltd., (2011) 330 ITR 470 SC. 6. We have given careful consideration to the contentions of learned counsel appearing for the parties and scrutinized the material on record. 7. The material on record would clearly show that the grounds raised by the assessee before the first appellate authority and the ITAT was only regarding imposition of interest under section 234B and 234C of the Act. It was the contention of the assessee that in view of the principles laid down by this Court in Kwality Biscuits case, no interest could be levied under section 234B and 234C of the Act. It was the contention of the assessee that in view of the principles laid down by this Court in Kwality Biscuits case, no interest could be levied under section 234B and 234C of the Act. The said contention has been rejected, according to us rightly by the authorities on the ground that when the assessment is made under section 115JA of the Act, in view of the provisions of section 115JA(4) of the Act, the provisions of section 234B and 234C would also be applicable and the Supreme Court, in a decision cited by the learned counsel appearing for the respondent in Rolta India Ltds case, has clearly considered the questions as to whether the interest under section 234B of the Act can be charged on the tax calculated on the book profits under section 115JA of the Act and whether the advance tax was payable on book profits under section 115JB and answered the said questions against the assessee and in favour of the revenue by holding that in view of the provisions of section 115JA(4) of the Act, the provisions of sections 234B and 234C of the Act would be applicable and decision rendered by this court in Kwality Biscuits case is held to be considered by the Supreme Court and it is observed at para 9 of the said judgment that decision of this court in Kwality Biscuits 'case was confined to the assessment made under section 115J of the Act. Accordingly, following the principles laid down in the above said decision, we hold that the authorities were justified in not following the decision of this court in Kwality Biscuits case and were justified in confirming the imposition of interest under section 234B and 234C of the Act as the assessment has been made under section 115JA of the Act. Accordingly, the substantial questions of law have been answered against the assessee and in favour of the revenue. The appeal is devoid of merit and accordingly it is dismissed. 8. Note : 'The above is true transcription of the judgment dictated to me by late Hon'ble Shri Justice V.G. Sabhahit presiding over the Division Bench with Hon'ble Shri Justice S. N. Satyanarayana in Open Court on 12-12-2011.