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2018 (8) TMI 1856 - AT - Income TaxNot accepting the claim of rate of tax applicable to domestic companies and/or co-operative banks also applicable to the Appellant, in accordance with the provisions of Article 26 (Non-discrimination) of the India-France tax treaty - DTAA - HELD THAT:- The issue is covered, against the assessee, by a series of orders passed by the various co-ordinate benches in assessee’s own case in this view of this undisputed position and the conclusions arrived at by the learned CIT(A) being in harmony with the views of the coordinate benches, we reject the grievance of the assessee. No interference is thus called for. Taxability of interest paid by Indian Branch Office of the assessee to its head office - subject to proving the assessee that it made such claim in its return of income filed in original for Assessment Year 2011-12 by way of notes to return that were uploaded with the same return of income - HELD THAT:- We find that the issue taxability of interest paid by the assessee to its head office has been decided in favour of the assessee by the Tribunal for Assessment Year 2000-01 and 2001-02 [2013 (7) TMI 1134 - ITAT MUMBAI] , Assessment Year 2002-03 and 2003-04, Assessment Year 2004-05 Assessment Years 2006-07 & 2007-08 and for Assessment Year 2010-11 - Decided in favour of assessee.
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