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2014 (2) TMI 381 - AT - Income TaxDisallowance of Interest – Held that:- The assessee made payments of interest to its overseas branches and also to others – the issue was not examined thoroughly during the assessment proceedings, considering the non attendance of the assessee and supply the relevant details - The request of the assessee is accepted for remanding the issue to the files of the AO for fresh examining after considering the Act/treaty – Decided in favour of Assessee. Disallowance of interest paid to Head Office and to other overseas branches - The issue for adjudication revolves around the prayer of remanding after setting aside the findings of the AO/DRP – there was merit in the prayer of the assessee - thus, the order of the AO and the DRP-1 and remand the matter to the files of the AO for fresh adjudication – Decided partly in favour of Assessee.
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