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2010 (12) TMI 282 - AT - Income TaxDTAA - Interest - During the course of assessment proceedings, the Assessing Officer noted that the assessee received Income-tax refund, which included interest on such Income-tax refund amounting to Rs. 12,44,428 - The Assessing Officer opined that interest earned on Income-tax refund could not be said to be the interest on funds connected with the operation of ships in international traffic - The interest on Income-tax refund is includible under Article 11 and the authorities below were justified in repelling the contention of the assessee for its inclusion in Article 8(3) – interest on Income-tax refund is chargeable to tax in the hands of the non-resident assessee as the same is arising in India.
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